Data Privacy Statement
Under General Data Protection Regulations from 25th May 2018
Who Are We?
Titan Talent Partners, 1003 Morningside Meadow Ln. Matthews, NC 28104 USA
Email: privacy@TitanTalentPartners.com
This Privacy Notice explains in detail what personal data we will process and how we will keep it safe. We want you to be fully informed about your rights and how we will use your data. We may need to update this Privacy Notice from time to time and if there are any significant changes we will let you know. You are welcome to request a current copy at any time or you can visit our website to view the latest version.
Titan Talent Partners is a recruitment business, offering both interim placement and executive search services to its clients and candidates. The Company must process personal data (including sensitive personal data) so that it can provide these services to you. In doing so, the Company acts as a data controller.
We are committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure service where we deal with your personal information. This means information that identifies you personally such as your name, photo or contact details or data that can be linked with such information in order to identify you.
Quick Guide to Contents
1) What personal information do we collect about you?
2) Where do we collect personal information about you from?
3) How do we use your personal information?
4) How long do we keep your personal information for?
5) Who do we share your personal information with?
6) Do we transfer your personal information outside the EEA?
7) What are your rights?
8) Complaints or Queries
1) What personal information do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information may include your name, contact details, family details, CVs/resumes, identification documents, educational records, work history, employment status and references.
We might sometimes also collect sensitive personal information about you, such as details of criminal convictions and ethnic origin.
We only collect sensitive personal information from you, and further process this data, where you have given your explicit consent or otherwise where permitted by law.
2) Where do we collect personal information about you from?
The following are the different sources we may collect personal information about you from:
- Directly from you. This is information you provide while considering or searching for a new opportunity (for example when you provide a CV) and/or during the different recruitment stages.
- From an agent/third party acting on your behalf.
- Through publicly available sources. We use a range of public sources including:
- Viadeo
- Facebook & Twitter
- Other social media platforms
- Company web sites
- Other information in the public domain
- By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
3) How do we use your personal information?
- To provide a requested service or carry out a contract with you
Where we are asked by clients under our Legitimate business interest to suggest candidates who may be appropriate for a specific role. At this stage, we only produce and provide publicly available information.
- Where we have your consent
We will contact you to discuss an opportunity and only provide further information to the client with further information you have given us with your specific consent.
- Where we have a legitimate interest
All the data we collect and process from the data subject will be used only in relation to our executive search and assessment activities. Legitimate interest means that we do not require consent from the data subject.
- Where we have a legal obligation
Where we are required by legal authorities or statutory requirements to disclose information under binding legal obligations.
4) How long do we keep your personal information for?
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
Where we hold them, we must also keep 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.
Where we have obtained your personal data as part of a recruitment process, we will retain it for a maximum period of 5 years unless we are engaged with you during that period. Should we wish to continue to hold data after five years, we will:
- Where we are holding data under legitimate interest, we will assess whether the legitimate interest still applies
- Where we have received consent, we will seek to contact the individual to ask for continued consent.
Stored personally identifiable data we have captured from the social networks Xing or LinkedIn will be deleted following the end of our communication unless you are interested in job referrals and an actual application process has been initiated.
5) Who do we share your personal information with?
We share your personal information with a client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. We may also share your personal information with a client who is interested in assessing potential candidates for future vacancies (ie during talent mapping and talent pipelining exercises).
We follow the same guidelines whether candidates are based within the EEA or outside. Where our client or a role is outside the EEA we might transfer personal information outside the EEA, but always using the same guidelines in obtaining Consent, as in 3 above.
We share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as referencing, qualification and criminal reference checking services (as required), verification of the details you have provided from third party sources, psychometric evaluations or skills tests. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our website, our business or the public.
If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide recruitment services to you, we may not be able to match you with available job opportunities.
It is important to note that we do not carry out automated decision making when making decisions about you.
6) Do we transfer your personal information outside the EEA?
For specific clients outside the EEA and relating to specific roles, we might transfer personal information outside the EEA but it will only be on the basis outlined in the preceding sections.
7) What are your rights?
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to the erasure of your personal data in certain circumstances;
- The right to restrict the processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Legal basis
The legal basis for processing the application data submitted by you is GDPR, Art. 6(1)(1)(b). Processing your data is necessary to make pre-contractual arrangements between you and any potential employers. GDPR, Art. 6(1)(1)(f) provides an additional legal basis. Our legitimate interest arises from the above-described purpose of referring you to potential employers which, because of the application initiated by you, is not contrary to your interests.
In the event that we collect your information through active searching, for example, in social networks, the legal basis for processing your data is GDPR, Art. 6(1)(1)(f). In this context, we have a legitimate business interest in recruiting personnel for our clients.
Data recipients
The recipients of candidate or applicant data are internal departments charged with processing your documents. In addition, we may transmit your data to selected employers (third parties), for whose employment offers you have applied, provided that you have been shortlisted as a candidate. In the event that you are found to be suitable for other vacancies, as well, your data will only be referred to the respective clients after you have given your express consent.
Rights of the data subject
As a data subject, you may raise the following claims if the relevant preconditions are met:
GDPR, Art. 15: Right to information
You have the right to request information from us at any time about which of your personal data we are processing at any time.
- GDPR, Art. 16: Right to correction
If your personal data is incorrect or incomplete, you can request that the information be corrected.
- GDPR, Art. 17: Right to deletion
Under the conditions specified by GDPR, Art. 17 you can request the deletion of your personal data
- GDPR, Art. 18: Right to restriction of processing
If the requirements of GDPR, Art. 18 are met you can request that the processing of your personal data be restricted.
- GDPR, Art. 21: Right of objection
You may, on grounds arising from your particular situation, make an objection against the processing of your data at any time.
Apart from the above rights of the data subject, you may at any time revoke your consent given according to GDPR, Art. 7(3).
Where you have consented to the Company processing your sensitive personal data you have the right to withdraw that consent at any time by contacting Titan Talent Partners at privacy@TitanTalentPartners.com or, if by post, the Managing Partner, Titan Talent Partners Inc., 1003 Morningside Meadow Ln. Matthews, NC 28104 USA
8) Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contactprivacy@TitanTalentPartners.com or, if by post, Managing Partner, Titan Talent Partners Inc., 1003 Morningside Meadow Ln. Matthews, NC 28104 USA
This Privacy Notice explains in detail what personal data we will process and how we will keep it safe. We want you to be fully informed about your rights and how we will use your data. We may need to update this Privacy Notice from time to time and if there are any significant changes we will let you know. You are welcome to request a current copy at any time or you can visit our website to view the latest version.
Titan Talent Partners is a recruitment business, offering both interim placement and executive search services to its clients and candidates. The Company must process personal data (including sensitive personal data) so that it can provide these services to you. In doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on your Curriculum Vitae, in an email to us, or we may collect them from another source such as a job board. We may also collect further data from interviews or telephone calls with you which may be stored and shared. The Company must have a legal basis for processing your personal data. For the purposes of providing you with recruitment services and/or information relating to your future career, we will only use your personal data in accordance with the terms of the following statement.
Collection and use of personal data
Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process it for the purposes of providing you with recruitment services. We may also provide career guidance, which may or may not be part of a recruitment process. We will seek your explicit consent to use your data for marketing purposes and you will have the option to unsubscribe at any time.
The legal bases we rely upon to process your data and to offer these services to you are:
Legitimate interest
Statutory obligation
Contractual obligation
Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is as follows:
You have supplied us with your personal data as you wish to receive recruitment services from the Company.
It is of mutual benefit to both you and the Company that we process your data for this purpose.
Recipient/s of data
The Company may process your personal data and/or sensitive personal data with the following recipients:
Our clients
Our candidates
Statutory/contractual requirement
Your personal data is required to be processed by the Company by law and/or to comply with a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and without it will be unable to provide our recruitment services to you.
Overseas Transfers
The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with recruitment services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
Where we hold them, we must also keep 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.
Where we have obtained your personal data as part of a recruitment process, we will retain it for a maximum period of 5 years unless we are engaged with you during that period.
Where the Company has obtained your consent to process your sensitive personal data, we will do so in line with our ‘Policy for managing sensitive personal data’, a copy of which is available on request.
Your rights
Please be aware that you have the following data protection rights:
The right to be informed about the personal data the Company processes on you;
The right of access to the personal data the Company processes on you;
The right to rectification of your personal data;
The right to erasure of your personal data in certain circumstances;
The right to restrict processing of your personal data;
The right to data portability in certain circumstances;
The right to object to the processing of your personal data that was based on a public or legitimate interest;
The right not to be subjected to automated decision making and profiling; and
The right to withdraw consent at any time.
Where you have consented to the Company processing your sensitive personal data you have the right to withdraw that consent at any time by contacting the Managing Partner, Titan Talent Partners Inc., 1003 Morningside Meadow Ln. Matthews, NC 28104 USA
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Managing Partner, Titan Talent Partners Inc., 1003 Morningside Meadow Ln. Matthews, NC 28104 USA