Talos 360 Privacy Policy

OVERVIEW

1.1 This privacy policy makes it clear how we process and protect your personal data. This includes any information that you submit to our online recruitment software and any information gathered on this website.

1.2 By using this site you are agreeing to your data will be held, stored and processed according to the policy detailed below. We comply with the GDPR and as such your data is securely stored and only accessed by relevant and authorised personnel.

1.3 The purpose of the data collection and the type of data requested is decided by the Data Controller. In this instance the Data Controller is Punter Southall Group 11 Strand.

1.4 The Data Controller uses a Data Processor in order to collect, store and securely transfer your data. In this instance your Data Processor is Talos 360 Basecamp, 4 Webster Court, Carina Park, Warrington, WA5 8WD. The Data Protection Officer for Talos 360 can be contacted at: info@talos360.co.uk

DATA SECURITY

2.1 The technology that we use has been designed with your security in mind. Our Data Processor’s servers are based in the UK and they deploy both technological and operational security measures along with internal policies specifically implemented to protect your data.

LEGAL BASIS

3.1 From the latest data protection regulations (GDPR) our legal basis for processing your data will be in the legitimate interest in using the information that you supply to us in order to process your job application and to provide you with information which may be of use.

3.2 The purpose of our data collection is to assess your suitability for the specific job role that you have applied for. We may also use this information to contact you about other similar job opportunities and may also statistically analyse your data.

3.3 We may also need to request and process your data if it is necessary for the performance of a contract or if we have a legal basis for doing so. This may include the data that you need to supply to us in order to satisfy the offer of a term of employment.

3.4 If we require your explicit consent to process any data as specified by GDPR then we will inform you of this consent requirement, and request your explicit “opt-in”, at the point of data entry.

WHAT DATA DO WE COLLECT?

4.1 The personally identifiable information that we identify, store and process on this site is that which is voluntarily provided to us. This includes (but not limited to):

Your CV
Cover letters
Personal information supplied such as your name, email address & phone number
Any details you enter into any application form
Any answers to questions that correspond with your recruitment preferences
Any supporting information that you provide to expand your candidate profile

YOUR DATA ACCESS RIGHTS

5.1 When it comes to your personal data you have the right to:

Rectify inaccurate or outdated information
Request to move your data (data portability)
Object to data processing
Withdraw your data consent at any time
Be forgotten
Ask for a copy of your data via a Subject Access Request (SAR)
Lodge a complaint with the UK’s Information Commissioner’s Office (ICO) or other relevant supervisory authority

5.2 If you think that there are any inaccuracies in your data then let us know and we will amend your records. We also provide reasonable access to our visitors for reviewing the data that you have provided to this website. In this instance please contact sar@talos360.co.uk with your request.

5.3 If you’d like to remove the data that you have supplied to us then you can do so by here and we’ll delete your records for you.

5.4 If you’re not happy with the manner in which your data has been processed you can submit a case to our internal complaints procedure by contacting dpo@talos360.co.uk. If you are not satisfied with the outcome of our investigation, you have the right to contact the ICO (http://www.ico.org.uk).

SHARING DATA

6.1 The data that you submit to this site may be:

Made available to the Data Controller
Made available to the Data Processor
Used to communicate with you about your application
Used to communicate with you in regards to recruitment
Used to supply you with relevant (optional) job alerts
Added to a searchable candidate database
Analysed for our internal statistics to improve processes

6.2 Sometimes information may be processed on our behalf by relevant third parties; this includes but is not limited to: video interviewing companies, payroll software, and HR software.

6.3 We will not collect your information for unrelated purposes without first requesting your consent.

6.4 In some cases, we may be compelled or permitted by the law, an official authority or regulatory requirements to process your personal information without your consent or knowledge, even after you have exercised your right to withdrawal, to be forgotten, or objected to processing. If this happens, we will only process the limited personal data that we are required to do so under these specific requirements.

LENGTH OF DATA STORAGE

7.1 If there is no activity on your candidate account for 2 years, it will be deactivated. You can also request to withdraw your details at anytime and thereafter your data will be fully anonymised for further protection.

PRIVACY POLICY CHANGES

8.1 Provided that compliance is maintained in regards to the General Data Protection Regulation (EU) 2016/679, we reserve the right to amend and modify this privacy statement for any reason and at any time.

Punter Southall Group Applicant Privacy Policy

Punter Southall Group means Punter Southall Group Limited registered at 11 Strand, London, WC2N 5HR with company number 04096788 and includes any of its subsidiary companies from time to time wherever registered or incorporated (together group companies or Group).

References to we or us or our mean Punter Southall Group and our group companies.

Introduction

Punter Southall Group and its group companies (PSG) (we, us or our) knows that you care how your information is used and shared and we appreciate your trust in us to do that carefully and sensibly. Your privacy is important to us and we are committed to protecting and respecting your privacy. We seek to ensure that our information, collection and processing is always proportionate.

Please ensure that you read this privacy notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you, so that you are aware of how and why we are using such information.

This privacy notice explains how we use and may share any personal data we may collect from you or is provided to us about you as part of our recruitment process. It applies to applicants at every stage of the recruitment process. This notice is non-contractual and we may therefore update it at any time.

Who we are

We are Punter Southall Group Limited and we are the Data Controller. This means that we are responsible for deciding how we hold and use personal information about you. This information is also used by our group companies. Our business contact details are:

Registered office:	11 Strand, London WC2N 5HR
Telephone:	03300 945000
Email:	hrservicedesk@puntersouthallgroup.com
Website:	www.puntersouthall.com

The contact details of our Data Protection Officer are:

Name:	Richard Garmon-Jones
Address:	11 Strand, London WC2N 5HR
Telephone:	020 3327 5182
Email:	data.protection@puntersouthallgroup.com

Personal data we collect

The Schedule appended to the end of this notice summarises the information we collect and use, how and why we do so, how we use it and with whom it may be shared. We will notify you of any changes to information we collect or to the purposes for which we collect and process it by updating this notice.

We and our service provider (of the Applicant Tracking System ‘ATS’, who works on our behalf) may use a variety of technologies, including cookies and similar technologies, to assist in collecting certain information, as is detailed below.

Personal data we obtain from third parties

We obtain information about you from other sources as follows:

Personal and relevant work related details of candidates.

Why we collect and use your personal data

We need to process your data in order to consider entering into an employment relationship with you and to meet our obligations under any contract of employment which we enter into with you. We also need to ensure that we comply with our legal obligations (e.g. checking your entitlement to work in the UK). We have a legitimate interest in processing your personal data during the recruitment process and for keeping records of the process.

We, or our service provider, of the ATS, use your information to manage and administer our recruitment and selection process. Further information on the lawful grounds for processing your information can be found in the Schedule appended to the end of this notice.

Where information may be held

Information may be held at our offices and those of our group companies and by third party agencies and service providers.

Our current ATS service provider does not currently store your personal data outside of the UK, for the purposes described in this Privacy Notice. Our ATS service provider will only transfer personal data to another country where the Company has provided consent for this, and the Company will then ensure that International Transfer Agreements or other applicable transfer mechanisms are in place to ensure an adequate level of data protection.

Keeping your personal information secure and protected

We take the security of data seriously. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Who has access to your data?

Your personal data will only be accessed and processed by authorised personnel who are directly involved in the recruitment exercise; those who have a legitimate need to access your data.

In particular, your data may be shared internally with members of the HR team, hiring managers involved in the recruitment process and managers in the business area with the vacancy.

We share your data with third parties for the following purposes. The recipient of the information will always be bound by confidentiality obligations:

• Enable application to be made and application process to be tracked;

Obtain pre-employment references from previous employers;

• Request background checks such as credit checks and criminal record checks.

How long we will keep your personal data for

If you have approached PSG directly we will retain your application data for 13 months from the last time you were active within our applicant tracking system.

If you have been introduced to us via a recruitment agency we will retain your application data for 6 months from the date of your last job application.

Any selection documentation will be retained for a period of 6 months from the selection decision.

How to access and control your personal data - Your rights

You have certain rights with respect to your information which are summarised below:

Right to be informed: you should be given a copy of this notice on application;
Right of access: you can ask for copies of all the information that we process about you;
Right to rectification: you can ask to have inaccurate information held about you corrected;
Right to erasure: you can ask for the information held about you to be erased (subject to certain criteria);
Right to restriction of processing: you can ask us to stop processing your information (under certain circumstances);
Right to data portability: you can, under certain circumstances, request that we transmit your personal information to another provider of services;
Right to object: you can object to your information being processed if our legal basis for processing your information is based on a “legitimate interest”;
Rights related to automated decision-making including profiling: the UK GDPR has provisions on automated individual decision-making and profiling. The Company does not currently utilise any automated decision-making or profiling in relation to recruitment.

If you would like to exercise any of your rights mentioned above, you can do so by writing or emailing our Data Protection Officer or the Recruitment team at the address detailed.

Your right to withdraw consent

You are not obliged to provide your personal data nor to consent to us processing it. Where you have provided consent for us to process your information you can withdraw your consent at any time. Please note: Withdrawal will not affect the lawfulness of processing prior to you withdrawing your consent.

You can withdraw your consent in the following ways:

In writing, to our Recruitment team or Data Protection Officer; or

By updating your account profile options or deleting your account altogether in the applicant tracking system by clicking on ‘Remove My Profile’.

However, if you withhold your personal data, decline to consent to processing, withdraw such consent or exercise any of your other rights in relation to your personal data, we will be obliged to act on the information available to us at that time. This may adversely affect you and/or limit your application process and in certain circumstances, we may not be able to proceed with your application altogether.

Your right to make a complaint

If you have a complaint about the way we process your personal data or think that we have not complied with your rights, you can make a complaint to our Data Protection Officer at the address detailed above.

We hope that the Data Protection Officer can resolve any query or concern you raise about our use of your information and we encourage you to raise any issues with them in the first instance, but you can also contact the Information Commissioner at the following address:

The Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113

Fax: 01625 524510

Website: www.ico.org.uk

Changes to this notice

Upon each login to the ATS you will be required to agree to the Terms and Conditions as outlined in this privacy statement. Please note these terms may be reviewed on a regular basis depending on business and legislative changes and it is your responsibility to review these terms prior to accepting.

Schedule

About the information we collect and hold

The information we collect	How we collect the information	Why we collect the information	How we use and will share the information
Title, name, home address, telephone number, personal email address, gender (if derived from title)	From you	To invite you to interview and inform you of the outcome at each stage of the selection process To administer appropriate record-keeping in our recruitment and selection practices To conduct background vetting/screening/investigations if appointed (including credit reference, criminal record checks, checks against fraud databases, address verification, academic qualifications and employer references)	In entering into/performing a potential contract with you Information shared with relevant managers and HR personnel In carrying out statutory checks. Information may be shared with other regulatory authorities as required
CV profile, work history, qualifications, experience, achievements and skills, and covering letter	From you	To identify and evaluate your suitability for the role you applied for To make a decision whether to invite you for interview, to conduct an interview with you and to make a decision whether to appoint you to the role To maintain your ATS account and identify any future employment potentials	In entering into/performing a potential contract with you Information shared with relevant managers and HR personnel
Information about your current level of remuneration including benefit entitlements	From you	To identify and evaluate your suitability for the role you applied for and to decide on the appropriate salary and benefits	In entering into/performing a potential contract with you
Immigration status*	From you and where necessary, the Home Office	To comply with our legal obligations To enter into/perform the potential contract we have with you	In carrying out right to work checks Information may be shared with the Home Office
Account password, application history, account usage	Automated monitoring of our ATS	To maintain your ATSaccount and identify any future employment potentials To preserve the security of your ATS account To monitor and manage access to our systems To protect our networks and personal data of applicants against unauthorised access or data leakage To ensure our business policies, such as those concerning security and internet use are adhered to	In protecting and carrying out our legitimate interests Information shared with relevant managers and HR personnel Passwords are not visible to any individual within PSG or the ATS
Interview notes and/or test outcomes, scorings and results	From you and the hiring manager	To identify and evaluate your suitability for the role you applied for To analyse and report on the recruitment process and its outcomes To comply with our legal obligations and to respond to and defend any legal claims	Information used to make hiring decision; shared with relevant managers and HR personnel
Employment history details, including start and end dates with previous employers (or self-employments) including references from previous employer(s) and HMRC records	From you and from our referencing company	To enter into the contract we have agreed with you To identify and evaluate your suitability for the employment relationship	In entering into/performing the contract we have with you. Any employment reference received by the Company will be considered to have been provided to the Company in confidence.

*We need you to provide this information to enable us to verify your right to work and eligibility for the position. If you do not provide this information, we may not be able to employ you.

PSGs represents and warrants that the data processing of any applicant data will be carried out with the knowledge of the applicant.