Cyber Talent Partners Privacy Notice
Last updated: 18th August 2022
Last updated: 18th August 2022
At Cyber Talent Partners Ltd (”We”) are committed to, and hugely passionate about, protecting and respecting your privacy. Whether you deal with us as a candidate, client or partner we will always make sure we do the right thing by you and that includes doing the right thing by your data.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
As of 31 December 2020, the UK left the EU, and UK GDPR is running alongside the EU GDPR. Your rights under the new UK GDPR and existing EU GDPR are set out in this notice. The EU is currently undertaking an adequacy assessment of the UK to determine if data transfer can continue as before. A decision is expected to be made by the end of June 2021.
The EU GDPR, UK GDPR and Data Protection Act 2018 (DPA) are regulations aiming to harmonise data protection legislation across UK and EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. We welcome this piece of legislation as it is all about understanding you and putting you first, which is what we do every single day.
Please read the following carefully to gain a deeper understanding of our views and practices regarding your most precious asset – your personal data. We will let you know all of the ins and outs of how we use it and, more importantly, look after it.
For the purposes of data protection legislations, the data controller is Cyber Talent Partners Ltd of Kemp House, 160 City Road, London, EC1V 2NX.
We are a specialist Cybersecurity recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Given the nature of what we do on behalf of our candidates and clients we have to collect personal data of the following stakeholder groups to ensure we can deliver (when you see the examples below things will make a bit more sense):
If we collect information about you it will be in order to carry out our core business and ancillary activities.
This is information about you that you give us by filling in forms on our site www.cybertalentpartners.co.uk (our site) or by communicating with us by phone, video calls, e-mail, personal meetings or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, enter a promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, company name, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country, identification documents, curriculum vitae and photograph, emergency information, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, browser type and version, and if you choose to share it, your location data. We do this to improve your experience on our website and where relevant direct you to the appropriate sub directory of our site for your specific geography. The net result should be that you are able to either find jobs easier or get a better understanding of whether we are the right recruitment partner for your organisation.
We will also store information about your visit, including referral information (should you choose to share it), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), along with any personally identifiable information you leave on our contact forms. We keep this information to ensure that the context of our communication with you as relevant as possible. We also store data from surveys that contribute to our research reports and keep your details in some instances in case you’d like a copy. You contributed to it so why shouldn’t you see the results? Ultimately, you don’t have to give us any of this data if you feel uncomfortable with it. The last thing we’d want to do is make you feel uncomfortable.
We also obtain information about you from other sources such as LinkedIn, Xing, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners such as management and umbrella companies, search information providers, credit reference agencies and criminal record checking agencies. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to send market updates directly to you or introduced you to a client (if you are a candidate).
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. To successfully match the candidates with the clients we need to retain information such as name, contact details, location, job title, area of expertise and additionally for candidates their curriculum vitae, education and training data, identification and right to work documents, salary and rate details.
To deliver our ancillary services we need to detail and map different market sectors with their relevant companies. We make note of organisation’s structures and who is currently employed in certain roles. This then facilitates either an executive search process or provides necessary understanding of who is responsible for the relevant teams and/or who may be the best point of contact to progress things further.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data
We will use this information:
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
We will disclose your personal information to third parties:
The lawful basis for the third-party processing will include:
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to strive to prevent unauthorised access.
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you haven’t requested your data to be removed. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@cybertalentpartners.co.uk Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act and the GDPR once it is in force.
A subject access request should be submitted to privacy@cybertalentpartners.co.uk
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to privacy@cybertalentpartners.co.uk