We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Talking Talent Limited collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
THE PERSONAL INFORMATION WE COLLECT AND USE
Information collected by us
In the course of developing our business and delivering coaching programmes and consultancy we collect the following personal information when you provide it to us:
1. Personal contact details, including name, job title, email address, telephone number (both for business contacts, client contacts, and coachees)
3. Employment information such as job title, employer name, office location, business phone number, business email address
4. Other relevant information as specified by the client (including level or grade, department, cost centre, employee ID number)Results of tests; psychometric or other
5. Parental leave dates
We may also collect some more sensitive data which is termed special category data. This includes:
1. Information regarding your mental health and wellbeing
2. Relevant medical history including information regarding pregnancies and children where relevant
3. Information on your sexual preferences and gender identity
4. Information about your race or ethnicity
Information collected from other sources
We also obtain personal information from other sources as follows:
1. Your employer when they recommend you for coaching
2. Door entry systems and reception logs
3. From cookies on our website for more information on our cookies please see our cookies policy
4. From a contact form on our website
5. Our IT systems for automated monitoring of our websites and other technical systems such as computer networks and connections, communications systems, and access control systems, email and other instant messaging systems
6. Publically available sources such as HMRC or companies house etc.
7. From a third party with your consent
How we use your personal information
We use your personal information to:
1. Administering, managing and developing our businesses and services
2. Providing information about us and our range of services
3. Making contact information available to Talking Talent employees
4. Identifying clients/contacts with similar needs
5. Describing the nature of a contact’s relationship with TT
6. Performing analytics, including producing metrics for Talking Talent leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals
we use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events. Business contacts are free to unsubscribe at any time
7. Administering the coaching programmes and courses
enable our coaches to provide the relevant coaching that you need
stay in touch with our alumni where we have their consent to do so
communicate with you about the course(s)
comply with our legal and regulatory requirements
to prevent and detect fraud
gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
ensuring business policies are adhered to such as those covering security and internet use
respond to a question, comment, feedback, complaint or where an individual wishes to access research and insight material produced by Talking Talent
to manage supplier relationships and to receive services from our suppliers
8. Talking Talent processes personal data using a customer relationship management system (the “TT CRM”). The TT CRM may collect data from Talking Talent email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between TT users and contacts or third parties.
9. We provide our individual coachees access to various applications managed by us. Such applications will contain their own privacy statements explaining why and how personal data is collected and processed by those applications. We encourage our individual coachees using our applications to refer to the privacy statements available on those applications.
Who we share your personal information with
We routinely share personal information with:
1. Third parties we use to help deliver our services to you, such as IT providers and psychometric test providers
2. Our insurers and brokers
3. Our bank (s)
4. Our Associate Coaches
5. Other third parties who help us to run a business, such as marketing agencies
Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
How long your personal information will be kept
1. Business Client contact information will be retained for as long as is necessary for the purposes outlined above.
2. Corporate Client contact information will be retained for the duration of the client contract. Thereafter, we will continue to hold your data so long as is necessary to respond to any questions, complaints or claims made by you or on your behalf
3. We will hold coachee data for the duration of the client contract, Thereafter we will continue to hold only your data so long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly and to keep records required by law
4. Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual)
Reasons we can collect and use your personal information
We rely on steps taken to enter into a contract or performance of a contract as the lawful basis for the majority of circumstances under which we collect and use your personal data.
Our legitimate interests are in marketing to you similar coaching programmes that we think might be of benefit to you, in marketing to third parties and business contacts who have previously expressed an interest in our services, in carrying out statistical analysis to help us manage our business, in preventing unauthorised access and modifications to systems, and in ensuring the confidentiality of commercially sensitive information.
If you consent to being a recipient of our alumni communications then we rely on that consent to continue to market to you.
Where we have legal and regulatory obligations, such as health and safety legislation, tax legislation, statutory returns, external audits and quality checks, we rely on those obligations as the basis for that processing.
Where we need to process personal data to provide coaching services, we ask our clients to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.
Transfer of your information out of the EEA
We may transfer your personal information to coaches who are located outside the European Economic Area (EEA) in order to provide coaching in your country of residence, including the following countries:
The United States of America
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that these countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to standards of safeguarding that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
1. fair processing of information and transparency over how we use your use personal information
2. access to your personal information and to certain other supplementary information
3. require us to correct any mistakes in your information which we hold
4. require the erasure of personal information concerning you in certain situations
5. receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
6. object at any time to processing of personal information concerning you for direct marketing
7. object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
8. object in certain other situations to our continued processing of your personal information
9. otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
1. email, call or write to us
2. let us have enough information to identify you, including your username and password where appropriate
3. let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
4. let us know the information to which your request relates
Keeping your personal information secure
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.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 303 123 1113.
Changes to this privacy notice
This privacy notice was published on 22 May 2018 and last updated on 22 May 2018.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to Christine.firstname.lastname@example.org, write to Christine Jones, Head of Global Operations, Talking Talent, 102 Crowmarsh Battle Barns, Preston Crowmarsh, Oxfordshire OX10 6SL or call +44 (0)1491 821850.