PRIVACY POLICY

Who are we?

Constello Talent Management Limited

We provide talent and career management services to clients looking to maximise their professional growth, as well as providing fringe operational services for businesses.

What does this policy cover?

We at Constello Talent Management Limited take your personal data seriously. This policy:

  1. sets out the types of personal data that we collect about you

  2. explains how and why we collect and use your personal data

  3. explains how long we keep your personal data for

  4. explains when, why and with who we will share your personal data;

  5. sets out the legal basis we have for using your personal data;

  6. explains the effect of refusing to provide the personal data requested;

  7. explains the different rights and choices you have when it comes to your personal data; and

  8. explains how we may contact you and how you can contact us.

What personal data do we collect about you?

In representing you, we regularly request, receive, process and maintain personal information about you.  All such information is referred to as “your information” in this notice.  This information may include:

Information provided by you, including information from documents and other forms we receive from you or while representing you;

Information about your professional activities related to transactions with non-affiliated third parties.

Information about your professional activities related to transactions with us or our affiliates.

We may also collect sensitive personal data about you, in the form of information relating to health. We only collect sensitive personal data from you and further process this data, where you have given your explicit consent.

From where do we collect your personal data?

The following are the different sources we may collect personal data about you from:

  • Directly from you. This is information you provide while searching for a new opportunity and/or during the different
    recruitment stages.

  • From an agent/third party acting on your behalf.

  • Through publicly available sources. We use the following public sources:

    • LinkedIn

    • Social Media

    • Job Boards

    • Public Notices/Signage

  • 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.

Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different job roles.

How and why we use your personal data

We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the process stage and onwards in that manner.

How long do we keep your personal data for?

We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:
a) our contractual obligations and rights in relation to the information involved;
b) legal obligation(s) under applicable law to retain data for a certain period of time;
c) our legitimate interest where we have carried out a balancing test (see legal basis below);
d) statute of limitations under applicable law(s);
e) (potential) disputes;
f) if you have made a request to have your information deleted; and
g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

Who do we share your personal data with?

In order to provide services to you, we may need to share your personal information.  The ways we may share your information include:  

Disclosing your information in connection with our efforts to procure engagements or employment for you, to process payments in connection with your professional activities, to respond to legal process, or to perform other services on your behalf that you have asked us to perform. 

Sharing your information with our affiliates (entities related to us through common ownership), so they may offer services to you and help us serve you better. 

Sharing your information with non-affiliated service providers such as banks, custodians, attorneys, and administrators, to enable them to perform services on our behalf, facilitate your professional activities, or as otherwise permitted or required by law.  

You may request that we limit our sharing of your information to our affiliates or others for the purpose of offering you services, by emailing us at privacy@constello.co.uk

How this Privacy Policy Relates to Your Agency or Representation Agreement

The purpose of this notice is designed to help you better understand how we handle your personal information and is intended to incorporate the terms of the representation agreement we may have with you.  Should any of the terms contained in this notice differ from those contained in your representation agreement with us, the terms of your representation agreement will control the use of any information you choose to provide or give us access to.  

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available opportunities.

Do we make automated decisions concerning you?

No, we do not carry out automated profiling.

Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.

Do we transfer your data outside the EEA?

At present we do not transfer personal data to countries outside the EEA.

What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

The right to access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.

The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data protability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

The right to object

You have the right to object to certain types of processing, including processing for direct processing marketing (i.e. if you no longer want t processing o be contacted with potential opportunities).

The right to complain

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

The right to withdraw

If you have given your consent to anything we do with your personal data, you have the right consent to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or

  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.

How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here:
privacy@constello.co.uk