CHARLTON HOWARD 

PRIVACY POLICY 

Charlton Howard, wholly owned subsidiary of Talent Point Ltd, (“we”, “our” or “Charlton Howard“) is committed to protecting the privacy of all individuals in respect of whom we hold personal information. Please read the following Privacy Policy which explains how we use and protect your information.  

For the purpose of the Data Protection Act 1998 or any replacement legislation including the EU General Data Protection Regulation (together, the “Data Protection Legislation”)the data controller is Talent Point Ltd of Unit 8, The Aquarium King Street, Reading, RG1 2AN, United Kingdom.  

This Privacy Policy covers: 

  1. The information that we collect from you 
  2. The information that we receive from other people  
  3. Our use of your information 
  4. How we share your information 
  5. Our legal basis for collecting and using your information  
  6. Our security, transfers we make outside of the EEA and data retention measures 
  7. Your rights in respect of your information 
  8. Accessing and updating your information 
  9. Changes to our Privacy Policy 
  10. Our contact information  

INFORMATION THAT WE COLLECT FROM YOU 

You may provide us with information about yourself including your name, contact details (being your address, email address and telephone number) and where relevant your CV (which may include information such as your work history, qualifications and other certifications as well as skills, qualities and attributes), reasons for seeking work and financial information (such as your salary). 

You may provide us with this information in a number of ways, for example by submitting forms in hard copy [or on our website], or by corresponding with us by email, letter, phone or in person. 

INFORMATION THAT WE RECEIVE FROM THIRD PARTIES   

We work closely with third parties (including, for example, our clients with whom we place our candidates) who may collect personal information from you. Where this is the case, the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your personal data will be used. 

We may also independently collect personal information about you from publicly available sources on the internet, such as company employee profiles, Linkedin and relevant job board websites. It is the responsibility of these sources to obtain the appropriate consent from the individual to display their information for us to access.    

USE OF YOUR INFORMATION 

We will primarily use your personal information to provide you with the recruitment advice and employment placement services (such as actively looking for new jobs and roles for you) that you have requested of us. However, we may also use your personal information to: 

  1.  keep in touch with you for the purposes of notifying you about appropriate long-term opportunities. In doing so, we may send you generic emails about jobs which we think may be appropriate for you. You can unsubscribe from these emails at any time; 
  2. combine personal information about you collected from third parties (see paragraph 2 above) with personal information you give to us and personal information we independently collect about you (for example from publicly available sources). For the avoidance of doubt, wwill only use this combined information for the purposes set out above and in accordance with this Privacy Policy; and 
  3. contact you as and when required in relation to your registration with Charlton Howard (including in relation to changes to this Privacy Policy or other Charlton Howard policies from time to time); 

If you change your mind about us using your data in the ways described in this Privacy Policy, please let us know by contacting us using the details set out in section 10 below. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.   

SHARING YOUR INFORMATION 

In order to provide our services to you we are required to share your personal information with certain third parties such as our clients (who will use your personal information for the purposes of evaluating your suitability for a position with them) and third-party suppliers (for example our IT providers). By submitting your personal information to us, you agree to such third parties processing your personal information. Charlton Howard asks all such third parties to treat your data securely.  

For the avoidance of doubt, we will not share your personal information with any client unless (a) it is in relation to a specific employment opportunity, and (b) we first obtain your prior consent to do so. 

In exceptional circumstances we may also disclose and/or transfer your personal information to a third party (i) if we undergo a change of control or any of our business or assets are sold or transferred to any third party (in which case we may disclose and/or transfer your personal information to the buyer or other recipient of us and/or our business or assets (as the case may be)); (ii) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (for example, a court order), or (iii) in order to protect our rights, property or the safety of our clients or website users. This may include exchanging personal information with other companies and organisations for the purposes of fraud detection and prevention.  

OUR LEGAL BASIS FOR COLLECTING AND USING YOUR INFORMATION 

We are required to collect and use personal information in accordance with, and in a manner justified by, the Data Protection Legislation. In doing so, we rely on one or more of the following grounds to legally collect and use your personal information: 

  1. we may process your personal information where this is necessary for the performance of the contract which we have with you (i.e. to provide recruitment advice and employment placement services to you as defined in 1.); and/or 
  2. we may process your personal information where you have consented to us doing so 

Where we rely on your consent to process any of your personal information, you may revoke your consent at any time. Any such revocation will not affect the lawfulness of any prior use of that personal information. 

SECURITY, DATA TRANSFERS OUTSIDE THE EEA AND DATA RETENTION 

We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your personal information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal information, we cannot guarantee the security of your data transmitted via email and/or our website; any transmission is at your own risk.  

The personal information that we collect from you will only be transferred to, and stored at, a destination within the European Economic Area (“EEA“), save where the data centres of any of our third-party suppliers are based outside the EEA.  It may also be processed by staff operating outside the EEA who work for one of our suppliers.  By submitting your personal information to us, you are acknowledging this transfer, storing or processing.  We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and the Data Protection Legislation.  This means that we will only allow third parties to access your personal information where those third parties (a) are in countries that have been confirmed by the European Commission to provide adequate protection to personal information; or (b) have agreed to provide all protections to your personal information as set out in the Data Protection Legislation.    

YOUR RIGHTS 

Should you have any queries or complaints in relation to how we use your information, please contact us via the details set out at section 7 below.  Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues. Further information about how to make a complaint can be obtained at www.ico.org.uk or by telephoning 0303 123 1113. 

Our website may, from time to time, contain links to and from third party websites.  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 websites or their related policies.  Please check these policies before you submit any personal information via these websites. 

ACCESSING AND UPDATING YOUR INFORMATION 

You have the right to see the personal information we hold about you and to ask us to: (a) make any changes to ensure that any personal information we hold about you is accurate and up to date; (b) erase or stop processing any personal information we hold about you where there is no longer a legal ground for us to hold it; or (c) transfer any information we hold about you to a specified third party. If you wish to do this, please contact us using the contact details set out below.  

CHANGES TO OUR PRIVACY POLICY 

Charlton Howard may amend this Privacy Policy at any time and where we make material changes to it we will provide notice on our website. By continuing to use our services and/or our website, you agree to the updated Privacy Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) our website and/or our services.  

CONTACT US 

All comments, queries and requests relating to our use of your personal information are welcomed and should be addressed to Charlton Howard, c/o Talent Point Ltd, Unit 8, The Aquarium King Street, Reading, RG1 2AN, United Kingdom; or call on telephone +44 0203 0111 501 

Talent Point have appointed a Data Protection Officer, Sara Satterthwaite, who can be reached at the above telephone number or via email at sara.satterthwaite@talentpoint.co 

LAST UPDATED: August 2019