Talvo is committed to protecting the privacy and security of personal data information. This privacy document describes how we collect and use your personal data information in the process of delivering our recruitment services to you. Our privacy policy is in accordance but not limited to the new General Data Protection Regulation (GDPR)

It is important that you read this document, together with any other privacy documents we may provide to you on specific occasions when we are collecting and/or processing your personal information so that you are aware of the process.

This privacy policy may be amended over time, with any changes posted on this page. Should you wish to keep up to date with any changes, please ensure that you visit this page regularly. If you have any questions after reviewing this document, please don’t hesitate to contact us at privacy@talvo.io


WHAT IS GDPR

The General Data Protection Regulation, or GDPR is the newly updated set of data protection laws that replaces the previous 1995 Data Protection Directive which current UK laws are based upon. The legislation is designed to ‘harmonise’ data protection laws across Europe, and ultimately give greater protection, security, and rights to individuals when it comes to their personal data information.

WHAT DOES IT REGULATE

The GDPR regulates the ‘processing’ of personal data. ‘Processing’ is a broad term and includes the:

• Collection of personal data
• Storage of personal data
• Transfer/sharing of personal data
• Use of personal data

The new legislation has also raised the bar when it comes to the power of the individual or ‘Data Subject’ when it comes to their own personal data. Data Subjects have extended rights including the access and right to be forgotten when it comes to their personal data.

WHAT IS PERSONAL DATA

Personal data is a broad term relating to any information that is related to a ‘Data Subject’, that can be used to directly or indirectly identify the person (e.g. name, photo, email address etc.). Talvo refers to all candidates, employees of clients, employees of suppliers and referee and emergency contacts as data subjects.

DATA PROTECTION PRINCIPLES

Talvo is the ‘data controller’, meaning we are responsible for determining how we hold and use your personal information. Under the GDPR, we are required to notify you of the information contained in this document.

To comply with the GDPR, the information processed by Talvo will always be:

• Processed lawfully, fairly and in a transparent way
• Collected only for valid purposes, and not used in any way that is incompatible with those purposes
• Accurate and kept up to date
• Kept if necessary and to the time scales detailed in the privacy policy
• Kept securely and safely on the designated database

Data should NOT be:

• Further processed in a manner that is NOT related to the initial legitimate purpose
• Processed unlawfully
• Be subject to accidental loss or access

HOW WE COLLECT YOUR DATA CANDIDATE DATA

• Directly from the candidate
• Third Party Sources (such as LinkedIn & Job Boards)

CLIENT DATA

• Directly from the client
• Third Party Sources (such as LinkedIn)

SUPPLIER DATA

• Directly from the supplier
• Third Party Sources

REFEREE & EMERGENCY CONTACTS

• Directly from a Candidate or Staff Member

WEBSITE USERS

• We collect your data automatically via cookies where appropriate via our website. If you would like to understand more about cookies, including how we use them and your options, please send an email to privacy@talvo.io

WHAT PERSONAL DATA WE COLLECT

At Talvo, we only collect and process personal data that is necessary to fulfil the purpose that enables us to function as a business and deliver top-class service to our candidates and clients.

CANDIDATE DATA

In order to fulfil our best practice and provide the best-suited employment opportunities to a Candidate, we need to collect and process certain information about you. Talvo will only request details about a candidate that will genuinely assist our search for your perfect employment such as:

• Name & DOB
• Gender
• Contact Details (Address, Phone Numbers, Email & Skype Addresses)
• Marital Status
• Proof of Address
• Employment History
• Education Details
• Skills & Qualifications
• Financial Information & Requirements
• Immigration status & right to work
• Valid ID
• Professional Online Profile Information (where applicable)
• Extra information you choose to tell us
• Extra information that your referees chooses to tell us
• Extra information that our clients may tell us about you, or that we find from other third-party sources such as job sites
• IP address

Records of our conversations and meetings may also be stored.

CLIENT DATA

If you are a client or possible client of Talvo, to fulfil our best practice and find candidates who are best suited to you, we need to collect and process information about your organisation and/or individuals at your organisation. Talvo will only request or source details about a client that will genuinely assist our search for your perfect employee, such as:

• Organisation Name
• Organisational Structure
• Contact Details (Address, Phone & Email)
• Employee Contact Details (Phone & Email)
• Employment Requirements
• Financial Information
• Business plans (where applicable)

Records of our conversations, meetings, registered jobs and placements may also be stored.

SUPPLIER DATA

Talvo requires a small amount of information about our suppliers to ensure that things work as they should. We need the contact details of individuals at your organization to communicate with you. Financial information such as bank details are also required so that we can pay for your services provided (if this is part of the contractual agreement between us).

REFEREE & EMERGENCY CONTACTS (received by Candidates & Staff)

To fulfill our best practice and offer best-suited employment opportunities, Talvo requests basic. Referee information so that we can contact you for one of our Candidates. If you have been listed as an Emergency Contact our Candidates or Staff Members, we require basic information so that we can contact you if necessary or in the unlikely event of an emergency.

WEBSITE USERS

We may gather information about your general internet use through the use of cookies. This information is statistical data and will not identify you personally.

HOW WE USE YOUR PERSONAL DATA

Talvo will only use your personal data when the law allows us to, in a lawful way. We typically use personal data information in the following circumstances.

CANDIDATE DATA

• To help a candidate find suitable employment or other work.
• Where it is necessary for our legitimate interest (or those of a third party), when your interest and fundamental rights do not overrise those interests.
• Where we need to create and perform a contractual agreement
• Where we need to comply with a legal obligation

Talvo typically shares your personal data with no one other than potential employers to increase your chances of securing the job or placement best suited to you. Talvo will not share your personal data with prospective employers or any other agencies until verbal or written consent is gained.

The more information we have about a candidate, the more tailored we can make our service

CLIENT DATA

The main reason for processing & using information about clients is to ensure that Talvo provides the most tailored service, this includes:
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• Identifying candidates who we think are best suited to your organisation
• To ensure that contractual arrangements between us can be properly implemented
• To help improve your organisational structure
• To offer any other value-added recruitment services
• Where we need to comply with a legal obligation

The more information we have about a client, the more tailored we can make our service. We will only share appropriate client data if approved by the client.

SUPPLIER DATA

The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements. We will only share appropriate supplier data once approved by the supplier.

REFEREES & EMERGENCY CONTACTS (received from Candidates and Staff)

We use referees’ personal data to assist our candidates in finding employment or placements best suited to them. To do so, we aim to verify their details and qualifications and ensure they are well-matched with the requirements of prospective employers & organizations. We also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. In some circumstances, we share the referee’s personal data information with our clients so they can perform background checks on a candidate.
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We use the personal details of a candidate or staff member’s emergency contacts in the case of an accident or emergency affecting that candidate or member of staff. We do not share Referee or Emergency Contact data.

WEBSITE USERS

We use your data through your computer in order to assist us in improving out website and therefore your experience of using it.

REFUSAL TO PROVIDE INFORMATION

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you and may also be prevented from complying with our legal obligations.

DATA SHARING

All our third-party partners are required to take appropriate security measures to protect your personal information in line with our policies and the GDPR legislation. Third parties will only process your personal information on our instruction and where they have agreed to treat the information confidentially and to keep it secure.

OVERSEAS TRANSFERS

Talvo may transfer only the information provided to us to countries outside the European Economic Area (EEA) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security and safety of your information.

HOW WE STORE YOUR DATA

At Talvo, we care about protecting your personal data. Therefore, we pledge to follow appropriate measures designed to prevent unauthorized access to, and the misuse of, your personal data. We place high value on our core privacy considerations and only store your data on our specially designed, secure & encrypted internal databases that are only accessible by our trusted & professional employees. Information within e-mails is confidential and is intended solely for the addressee. Access to emails by anyone else is unauthorized.

All Talvo’s employees are trained fully in the lawful practice of the GDPR legislation.

PERSONAL DATA BREACH NOTIFICATION

In the unlikely event of a security incident that results in a breach of personal data, Talvo will assess the risks of the breach and escalate the issue to the ICO and notify the individual within 72 hours if required. As detailed above, we have specially designed measures to ensure that all precautions and processes are implemented to prevent a security incident that could lead to a breach of personal data.

HOW LONG DO WE KEEP YOUR DATA FOR

Unless a request is made to have your data manually deleted, your personal data will be securely stored for up to 5 years from the date of last activity or contact. The conduct of employment agencies and employment business regulations 2003, require us to keep work-seeker records for at least one year from at least (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We must also keep (when applicable) your payroll records, holiday pay, sick pay, and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security, and tax legislation.

YOUR DATA RIGHTS

Under the GDPR, Data Subjects have extended rights when it comes to the access and use of their own personal data that we have. All rights are detailed below including how to exercise these rights:

RIGHT OF ACCESS

If you would like to obtain access to, or info about the processing of, your personal data please get in touch via privacy@talvo.io and we will provide the requested information within 28 days of your request. Please note that verification of your identity will be performed using reasonable means.

RIGHT OF RECTIFICATION

If you believe that the personal data we have stored is incorrect, please get in touch via privacy@talvo.io and we will update the information accordingly within 28 days of your request.

RIGHT OF ERASURE

In certain circumstances (for example, if you believe your data has been processed unlawfully), you have the right to request that your personal data be ‘erased’ from our records and any third parties. If you would like your data erased (based on a valid circumstance), please get in touch via privacy@talvo.io and we will respond to your request within 28 days. If we agree to erase your data, please note that under general assumption we will keep a note of your name on our register of individuals who would prefer not to be contacted. Therefore, we will prevent the chances in the future of you being contacted, and data collected in unconnected circumstances. If you do not want us to keep your name, please inform us.

RIGHT OF RESTRICTION

In certain circumstances (for example, if you believe your data has been processed unlawfully), you have the right to request a limitation on the way we process & use your personal data. If you would like to request the restriction of your data (based on a valid circumstance), please get in touch via privacy@talvo.io and we will respond to your request within 28 days. If we agree to your request we will prevent the processing of your personal data as per your request, however, please note that your data will still be stored.

RIGHT TO DATA PORTABILITY

You have the right to transfer your data from us to another data controller. We will happily assist you with this – by directly transferring your data for you or by providing you with a copy in readable format.

In circumstances where we have obtained your consent to process your personal data for certain activities (such as profiling your suitability for a role) or consent to market you as a candidate, you may withdraw your consent at any time by sending your request of withdrawal to privacy@talvo.io. We will respond to your request within 28 days.

RIGHT TO OBJECT

If we are using your data as we deem it necessary for our legitimate interest to do so, and you do not agree, you have the right to object. If you would like to log a request an objection, please send your objection to privacy@talvo.io and we will respond to your request within 28 days.

RIGHT TO LODGE A COMPLAINT

If you have any comments, questions, or concerns about the contents of this Privacy Policy or the way in which we use your information, we encourage you to first contact us using our contact details below:

Talvo Ltd
Email: privacy@talvo.io
Appleyard
170 New Road
Chilworth
Surrey
GU4 8LX

If we cannot resolve your concern or if you believe you have suitable grounds for a formal complaint against Talvo’s use of your personal data, please use the below details as your point of contact:

Phone: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

LAWFUL BASIS FOR DATA PROCESSING DATA

The GDPR underlines that a company must have a valid lawful basis to process personal data. Talvo will rely on two of the lawful basis:

• Consent
• Legitimate Interest

Each lawful basis will be used for different stages of our data processing procedure which is detailed in this document.

CANDIDATE DATA

When a candidate has actively signed up to a job board website or has connected with or selected the ‘I am available to recruiters’ option on professional social media sites, they have done so in the interest of finding employment through employers or agencies accessing their personal information. We believe that it is reasonable for us to use the personal data that you have posted on these sites to offer and provide our recruitment services to you by sharing that information with prospective employers and assessing your skills against our list of vacancies.

The legitimate interest of Talvo as a recruiter to fill available vacancies is not overridden by any interests or rights of candidates, but in fact, are aligned with the interests of the individual in finding a job.

If a candidate has provided information to Talvo directly (and this information is not available on job board websites), we will request verbal or written consent before processing this information.

CLIENT DATA

To fulfil our best practices and to provide you with the best service possible, we store client data and/or the personal data of individual contacts at the organization. We source and store personal data information in the form of contact details of a potential client's HR or Hiring Manager to make contact and offer our recruitment services and ultimately fill the vacancy with the most suitable candidate.

The legitimate interests of Talvo as a recruiter are not overridden by any interest or rights of the individual, but in fact, are aligned with the interest of the individual filling the advertised position.

Talvo believes that the storage and use of client data are necessary for our legitimate interests as a company that provides top-class, tailored recruitment services to you.

SUPPLIER DATA

We store and utilize the personal data of your organization and or individuals in your organization to enable the request of your services, as and when required. We store your financial details to pay you for your services.

SPECIAL AND SENSITIVE PERSONAL DATA

Special categories of personal data can be considered as particularly sensitive, and therefore require a higher level of protection as well as further justification for processing. Talvo may process special categories of data with your explicit verbal or written consent.

CHANGES TO THIS PRIVACY DOCUMENT

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy document accordingly. We may also notify you in other ways from time to time regarding the processing of your personal information.

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If you have any questions about this, please contact us via email at privacy@talvo.io