Talent Drive Ltd Recruitment Privacy Policy

Version Date: 28 April 2025
Contact: Martin Smith, Managing Director, martin@talentdrive.co.uk

Talent Drive Ltd (‘the Company’) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including special category data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with this privacy statement. At all times, we will comply with current data protection laws.

1. Collection and use of personal data

Purpose of processing and legal basis
The Company will collect your personal data (which may include special category data) and will process your personal data for the purposes of providing you with work-finding services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you

When processing special category data (such as health information or criminal convictions), we rely on your explicit consent or where processing is necessary for employment-related legal obligations.

Legitimate Interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data, our legitimate interests include:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to you and our clients;
• Contacting you to seek your consent where we need it;
• Giving you information about similar products or services that you have used from us recently;
• Ensuring compliance with legal obligations, industry regulations, and safeguarding standards.

Statutory/Contractual Requirement
The Company has certain legal and contractual requirements to collect personal data (e.g., to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements). Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect, we may not be able to continue to provide work-finding services to you.

2. Information to be provided when data collected from subject

Categories of Data
The Company has collected the following personal data on you:

Personal Data:

• Name, address, mobile no., email
• National insurance number
• Nationality (through right to work check)

Special Category Data:

• Health information including whether you have a disability
• Criminal conviction history

Source of the Personal Data
The Company sourced your personal data/special category data:

• From jobs boards or LinkedIn
• A former employer
• A referee whose details you previously provided to us
• Software providers who we use to support our services including Bond Adapt
• Through cookies as detailed below

Where your personal data is collected indirectly (for example, via a jobs board), the Company will inform you within 30 days of obtaining the data, or at the time of the first communication if earlier.

3. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, 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.

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. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your special category data, we will do so in line with our retention policy. Upon expiry of that period, the Company will seek further consent from you. Where consent is not granted, the Company will cease to process your personal data.

4. Your rights

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 to withdraw consent at any time.

Where you have consented to the Company processing your personal data, you have the right to withdraw that consent at any time by contacting Martin Smith at martin@talentdrive.co.uk. Please note that withdrawal of consent does not affect any processing done prior to the withdrawal.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

5. Cookies

We may obtain data about you from cookies. These are small text files placed on your device when you visit our website. They help the site function properly, improve efficiency, and provide information to us about how visitors use the site.

Cookies we may use include:

• Necessary cookies (essential for the website to function)
• Analytical cookies (to monitor performance)
• Functionality cookies (to remember your preferences)

Most web browsers allow some control of most cookies through browser settings. To find out more about cookies, please refer to our separate Cookie Policy. Please note that if you disable cookies, some features of our website may not work as intended.

6. Log Files

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

7. Links to external websites

The Company’s website may contain links to other websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site, we encourage you to read the privacy statements of every website that collects personally identifiable information.

8. Sale of business

If the Company’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

9. Data Security

The Company takes every precaution to protect users’ information. All data is stored securely on cloud-based technology protected by firewalls, browser certification technology, and password protection.

Only employees who need the information to perform specific jobs (for example, consultants, accounts staff or marketing assistants) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, the use of email and the internet is not entirely secure, and for this reason, the Company cannot guarantee the security or integrity of any personal information transferred via email or the internet.

If you share a device with others, we recommend that you do not select the “remember my details” function.

For questions about website security, you can email Martin Smith at martin@talentdrive.co.uk.

10. Profiling and Marketing Transparency

We may use limited profiling techniques to tailor our communications, such as analysing your skills, location, and previous roles to suggest the most relevant job opportunities or services. Profiling will not result in any automated decision-making that affects your legal rights.

11. Marketing Communications
We may use your personal data to send you information about opportunities, services, events, industry updates, or other marketing material which we believe may be of interest to you. This may include newsletters, job alerts, promotional campaigns, surveys, and other recruitment-related communications.

The legal basis we rely on for sending you marketing communications is your consent or our legitimate interest in keeping you informed of relevant services and opportunities.
You have the right to opt out of receiving marketing communications at any time. You can do this by:

• Clicking the “unsubscribe” link in any marketing email we send you; or
• Contacting Martin Smith at martin@talentdrive.co.uk to request removal from marketing communications.

Please note that opting out of marketing communications does not affect our ability to contact you about specific job opportunities or work-finding services that are relevant to your profile.

We will never sell or share your personal data with third parties for their own marketing purposes without your explicit consent.

12. Changes to this privacy statement

We may update this privacy statement from time to time. We will post any changes with revision dates. If we make any material changes, we will notify you.

13. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it, please contact: Martin Smith, Managing Director at martin@talentdrive.co.uk.

You also have the right to raise concerns with the Information Commissioner’s Office (ICO) on 0303 123 1113 or at https://ico.org.uk/concerns/, if you believe that your data protection rights have not been adhered to.

ICO Contact Details:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.