Privacy

At TalentDOC Limited (TalentDOC, “we”, “us”, and “our”) we understand your privacy and personal data are important to you. We commit ourselves to respecting and valuing the privacy of visitors, service users and other individuals with whom we work (Users) while using our website (Our Site), www.TalentDoc.co.uk, our App or other development instruments (tools). As part of this commitment, we have designed Our Site with the new General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) in mind.

Our policy explains your rights under this new law and becomes effective as of 25 May 2018. By continuing to use our site and apps after this date, you agree to our terms.

In short, we only collect and use the minimum personal data we believe to be required to perform our services for you and for the research we conduct. We do this in ways that are described in our policies and consistent with our obligations and your rights under the law.

This document summarizes the information we gather, how we use that information and who has access to that information. It also describes your rights in relation to that information, how long we keep it and who you can contact for more information.

Although you do not have to provide all the personal information requested, if we ask and you refuse, we may be limited in our ability to provide all the information or services you are seeking from us.

This policy also contains our Cookies policy. We use the minimum number of cookies we believe to be necessary to deliver a secure, personalised service. We will consider your use of our site as acceptance of our cookie policy.

Please read this Privacy & Cookies Policy (Privacy Policy) carefully and contact us with any questions. We accept your first use of Our Site as acceptance of our Privacy Policy. As a lot of time may pass between your uses, we will also occasionally ask you to reconfirm your understanding to give you the opportunity to change your mind based on each tool you are using. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings:

    • “Account” means an account required to access and/or use certain areas and features of Our Site.
    • “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in How Do You Use Cookies?.
    • “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
    • “Processing” means the collective acts associated with collecting, handling, protecting or storing of your personal data.
  2. Information About Us

    Our Site is owned and operated by TalentDOC Limited, a company registered in England under company number 11273863.

    • Registered address: 35 Westgate, Huddersfield, United Kingdom, HD1 1PA.
    • Data Protection Officer: Maninder Obhrai
    • Email address: contact@talentdoc.co.uk
    • Postal Address: 35 Westgate, Huddersfield, United Kingdom, HD1 1PA.
  3. What Does This Policy Cover?

    This Privacy Policy applies to our Users’ use of Our Site, tools and/or our Services. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other organisations, services or websites. As such, we advise you to check the privacy policies of any such website before providing any data to them.

    However, in principle, when selecting service partners we only contract suppliers or organisations who are GDPR compliant, who are headquartered and governed by governments who establish reciprocal laws and agreements in line with GDPR (such as Privacy Shield) or who have contractually committed to their ability and willingness to be bound by our GDPR policies.

  4. What Are My Rights?

    Under the GDPR, you have the following rights which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data.
    2. The right to access the personal data we hold about you.
    3. The right to have our personal data rectified, if any of your personal data held by us is inaccurate or incomplete.
    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to data portability. This means that you if you have provided personal data to us directly and meet the following criteria, you can ask us for a copy of that personal data to re-use with another service or business in most cases.
      • We are using it with your consent or for the performance of a contract.
      • That same data is processed using electronic means.
    8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in the How Do I Contact You? section of this policy.

    Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

    If you have any questions or complaints about the way we process your personal data, or would like to exercise one of your rights, please contact us and we will do our best to rectify your concerns.

    Should you wish to file a complaint with the UK regulator, please contact the Information Commissioner’s Office (ICO).

  5. What is Personal Data?

    Personal data and information (“personal data”) is defined by the GDPR as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    In simpler terms, personal data is any information about you that enables you to be identified. Personal data covers information such as:

    1. User’s full name
    2. Email and postal addresses
    3. Mobile and telephone numbers
    4. Identity documents (e.g. passports, drivers licences)
    5. Identity numbers (e.g. National Insurance/Social Security, bank accounts)
    6. Career and educational documents (e.g. qualifications, CVs, recruiting and employment information)
    7. Electronic location data and other online identifiers
  6. What Data Do We Collect?

    Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data. Please also see the How Do You Use Cookies? section on our use of Cookies and similar technologies:

    1. User’s full names
    2. Contact information including email address and mobile phone number
    3. Employer and title
    4. Demographic information such as nationality, age, gender (special information)
    5. Other information relevant to leadership development surveys
    6. Business services interests
    7. Other information when you report a problem on our site
    8. A record of the correspondence if you contact us
    9. Details of visits to our sites

    Note: We understand the importance of protecting children’s privacy and we never knowingly collect private information about individuals under the age of 18.

  7. How Do You Collect My Personal Data?

    We collect information from your leadership development partner (e.g. universities, schools, employers, training companies, coaches) that would like to utilise our tools in support of your development activities with them. Some examples of how others might provide data to us include, but are not limited to:

    1. Contacting us by phone or email to explore management development survey with your staff
    2. Participating in a development or learning program with a School, training provider or executive coach
    3. Providing us with business cards or referring us to another individual
    4. Your colleagues’ participation in our development surveys that require Rater nominations for feedback
  8. How Do You Use My Personal Data?

    Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

    1. Providing and managing your Account
    2. Providing and managing your access to Our Site
    3. Personalising and tailoring your experience on Our Site
    4. Supplying our services to you. Your personal details are required in order for us to enter into a contract with you and to deliver it
    5. Personalising and tailoring our services for you
    6. Communicating with you, including responding to emails or calls from you
    7. Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us
    8. Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your use of our Assessment specific processes, Assessments, Reports, Dashboard and enhanced security features
    9. Producing development reports over time for your personal completion of both nominated and self-initiated development activities
    10. Contacting you (around the scheduled expiry of your personal data) for a decision on your desire to anonymise or continue with our services
    11. Creating anonymised, normative databases to provide you with context for your professional development results and for research purposes

    With your permission and/or where permitted by law, we may also use your personal data to contact you by email or telephone in response to your queries or with information on our new products and services.

    We never sell your personal data and you will not be sent any unlawful marketing or spam. We do not use your personal information for automated decision making or profiling.

    We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out of marketing communications.

    Our Site only uses cookies we feel are important to delivering and improving the service we have promised. We use a limited number of cookies, both internal and  third-party Cookies, as detailed in How Do You Use Cookies? section. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

  9. How Can I Correct Any Errors or Incomplete Data?

    We also want to ensure the data we hold on you is correct and complete. If you find any incorrect or incomplete personal information in the information your leadership development partner provided to us, please contact your learning development provider to correct the information first. For information you provided to us, please contact us to correct or complete your information.

    In the unlikely event that we have disclosed any of the affected personal data to third-parties, we will inform them of any changes that need to be made to that personal data.

    Data corrections do not affect your retention timeline.

  10. How Long Will You Keep My Personal Data?

    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected unless you request otherwise. In fact, we will keep your data for three (3) calendar years at which point you will have the opportunity to decide if you would like to continue storing your data with us, or proceed with our standard anonymisation and deletion process. If we don’t hear from you before the three (3) calendar year expiry date, we will anonymise and delete your personal data. The following table describes more about our data retention timelines.

    User Data Retention Timeline and Process

  11. How and Where Do You Store or Transfer My Personal Data?

    We store your personal data centrally in the UK. We will only transfer your personal data for processing to countries that the European Commission has deemed to provide an adequate level of personal data protection. Examples include the US/EU and US/Switzerland Privacy Shield or others who have agreed contractually to be bound by our privacy policies. More information is available from the European Commission. This means that your data will be fully protected under the GDPR.

    With transferral of data to Users, we’ve taken it one step further. We will transfer your data to you, wherever you are, or to your Coach, at their location, if you have granted report viewing permission to her/him for the period of your programme. We’ve designed our business processes to reduce the transferral of personal data and the number of others involved in processing your data to a minimum.

    Please contact us using the details in the How Do I Contact You? section for further information about the particular data protection mechanism used by us when transferring your personal data to a another country.

  12. Do You Share My Personal Data?

    We will not share any of your personal data with any third parties for any purposes, subject to one important exception: legal requirements. Our research data is also anonymised.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  13. How Can I Control My Personal Data?

    In addition to your rights under the GDPR, set out in the What Are My Rights? section, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).

  14. Can I Withhold Information?

    You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

    You may restrict our use of Cookies. For more information, see How Do You Use Cookies?

  15. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can:

    1. Contact your learning development partner for your data provided to us, and/or
    2. Ask us for details of all your personal data and/or a copy of your personal data held by us (where any such personal data is held). This is known as a “Subject Access Request” (SAR).

    All SARs should be made in writing and sent to our DPO by one of the following 2 addresses to the Attention of the Data Protection Officer, Maninder Obhrai:

    1. Email address: contact@TalentDoc.co.uk
    2. Postal Address: 35 Westgate, Huddersfield, United Kingdom, HD1 1PA.

    We will respond to your SAR within one (1) calendar month from the date of your request or the date of any additional information we need from you to process your request. We will aim to provide a complete response, including a copy of your personal data within that time

    In some complex cases, however, more time may be required. In these cases we commit to providing your information within three (3) calendar months from the date we receive your request or from the date of any additional information we need from you to process your request. You will be kept informed of our progress.

    There is not any charge for a SAR, unless your request is deemed ‘manifestly unfounded or excessive’ (e.g. repetitive). In this case, we may require a fee to cover our administrative costs in responding.

  16. How Do You Use Cookies?

    Our Site may place and access certain first-party and third-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us; third-party cookies are those placed by website, services, and/or parties other than us.

    We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. All Cookies used by Our Site are used in accordance with current Cookie Law.

    Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Some cookies are not required for the functioning of our site and are “not strictly necessary”. For “strictly necessary” cookies, we will not ask for your consent. On the other hand, before “not strictly necessary” Cookies are placed on your computer or device, you will be shown a “request for your consent” option. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. If however, you wish to deny consent to the placing of Cookies, certain features of Our Site may not function fully or as intended.

    We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly. This includes, but is not limited to, login and personalisation settings.

    The following first-party and third-party Cookies may be placed on your computer or device:

    Name of Cookie Purpose Type/Provider Strictly Necessary?
    jwt Used to determine an authenticated user, for the length of their session. First-party / TalentDOC Limited Yes
    language Used to determine the language to display the website in, for the length of the session. First-party / TalentDOC Limited Yes
    accepted-cookies To determine whether the user has accepted cookies. First-party / TalentDOC Limited Yes
    _ga Used to track users for analytics purposes. Third-party / Google Analytics No
    _gat_gtag_UA_118301762_1 Used to track users for analytics purposes. Third-party / Google Analytics No
    _gid Used to track users for analytics purposes. Third-party / Google Analytics No
    __cfduid Cloudflare’s _cfduid cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. Third-party / Cloudflare No
  17. How Do I Contact You?
    • To contact us about anything to do with your personal data and data protection, including to make a Subject Access Request/SAR, please use the following details and be sure to include “for the attention of Data Protection Officer: Maninder Obhrai”.
    • Email address: contact@talentdoc.co.uk
    • Phone: +44 (0) 207 482 0324
    • Postal Address: 35 Westgate, Huddersfield, United Kingdom, HD1 1PA.
  18. Changes To This Privacy Policy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted here on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.