Privacy Policy

This privacy notice is issued on behalf of the Thryve Talent Ltd Group so when we mention Thryve Talent Ltd, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Thryve Talent Ltd Group responsible for processing your data. Thryve Talent Ltd is the controller and responsible for this website.

This notice sets out the basis on how we look after and process your personal data which we collect or which is provided to us and tells you about your privacy rights and how the law protects you.

The General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) took effect across all EU Member States, including the UK, on 25 May 2018. Although the UK has now left the EU, the GDPR continues to have direct effect in the UK until the end of the transition period (probably end of June 2021) as the EU-UK Trade and Cooperation Agreement contains a bridging mechanism that allows the continued free flow of personal data from the EU/EEA to the UK. Once the transition period is over, the GDPR will become part of domestic law referred to as ‘the UK-GDPR.’ Thryve Talent Ltd will comply to the Data Protection Act 2018 (DPA 2018) and UK GDPR, and the EU GDPR in case we process domestic personal data and offer goods and services to EU residents. The GDPR is enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Your new rights under the GDPR are set out in this notice.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

If you are an employee of ours, or work for us under any other contract for services, then please refer to our Employee Privacy Notice for further information on how we process your data and keep it secure.

Contact/Controller Details

For the purposes of data protection legislation in force from time to time the data controller is Thryve Talent Ltd of St. Magnus House, 3 Lower Thames Street, London, EC3R 6HD.

Thryve Talent Ltd is a registered Data Controller with the Information Commissioner’s Office (registration number: ZA390787).

Our nominated data privacy manager is John Lennon who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact John Lennon. using the details set out below:

Email address: dataprotection@thryvetalent.com

Postal address: St. Magnus House, 3 Lower Thames Street, London, EC3R 6HD

Telephone number: +44 (0)203 146 8757

Our nominated EU Data Representative, according to Art. 27 EU-GDPR, is: Jochen Curth - TÜV-certified DPO

Email: eu-representative@thryvetalent.com Hamburg - Germany

Who we are and what we do

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services including training, outsourcing, and consulting. We collect the personal data of the following types of people to allow us to undertake our business;

• Prospective and placed candidates for permanent or temporary roles;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Current and former employees, consultants, temporary workers.
• Referees of candidates and/or prospective employees/workers and
• Users of our website.

We may collect, use, store and transfer different kinds of personal information about you to carry out our core business and ancillary activities.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Information you give to us or we collect about you.

This is information about you that you give us by filling in forms on our website www.thryvetalent.com (“our site”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, apply to our advertised jobs, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site or give us some feedback or you have uploaded a CV and consented to a third party such as job boards sharing this information.

The information you give us or we collect about you may include your name, address, private and/or corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom or Europe (such as your passport or other photographic identification), employment history, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website and other similar information.

This information will take on of the following formats:

Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our sites.

Profile Data includes your username and password, purchases or orders made by you.

Usage Data includes information about how you use our sites, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate data around your usage of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories Data

We usually do not (further to Passport copies below) collect the following “special categories” of more sensitive personal information including information about your health, including any medical conditions and health and sickness records (Special Categories Data). In the event we do, we will request your explicit consent for this.

Passport Copies

As part of the legal requirements placed on us, or our clients, to verify the identity of candidates and workers, as well as your right to work in the UK, EU and/or USA, we do collect and retain copies of your passports. We will obtain your separate, explicit consent to do this at the time we take the copy. Please note: We kindly request that you do not provide us with any Special Category Data (including within the content of your CV) unless you are specifically requested to do so.

Information we collect about you when you visit our site.

Regarding each of your visits to our site we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system, and platform.

• If you consent with specific cookies other than strictly necessary cookies: tracking information about your visit, including the full Uniform Resource Locators (URL),] clickstream to, through and from our site (including date and time), services which you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we obtain from other sources.

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations from third parties. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including companies within our Group of companies, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers (such as Google located outside of the EU), search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services. These include the following organisations: Linkedin, Monster, Dice, Xing, Indeed, Stackoverflow, Angellist, Sonovate, Quickbooks, Bullhorn, Google Analytics (for full and/or current third party details please contact us at info@thryvetalent.com).

We may also receive personal data from your current employer, a referee, or if you are employed by an umbrella/payroll company or personal service company, from them. Please note: In these circumstances, when you are engaged through such a company, we will be relying on your employer to ensure they have established a legal basis for processing your data with you. Our basis for the ongoing processing of your data will become subject to a contract between us and that company.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service we are providing to you, but we will notify you if this is the case at the time.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you. ‘Performance of a contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or with your employer/prospective employer or to take steps at your request before entering into such a contract to which you are a party.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. ‘Legitimate Interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Where we need to comply with a legal or regulatory obligation. Where we need to comply with a legal or regulatory obligation. ‘Comply with a legal or regulatory obligation’ means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to Special Categories Data, Criminal Convictions and Offences Data and sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing info@thryvetalent.com

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the tables below.

Candidates:

For candidates, we may collect and process your personal data as follows:

add further cookie information in detail

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information inside and outside of the EEA

(European Economic Area)

We will share your personal information with:

(1) Internal third parties such as any employee or officer of any member of our group both in the EEA and outside of the EEA.

(2) Selected third parties including:

• clients for the purpose of introducing candidates to them in relation to a resourcing requirement;

• candidates for the purpose of arranging interviews and engagements;

• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;

• subcontractors including email marketing specialists, event organisers, payment and other financial service providers;

• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;

• analytics and search engine providers that assist us in the improvement and optimisation of our site;

• credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you; and

• HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.

(3) We will disclose your personal information to other third parties as follows:

• In the event that we sell, transfer, buy or merge any parts of our business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. Further, if thryve Talent Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of thryve Talent Ltd our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (” EEA”).

It may be transferred to third parties, including our employer clients, outside of the EEA for the purpose of our providing recruitment services. However, we will always ensure we have your consent to do this.

Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers (e.g. from the United States of America), we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US. For further details, see European Commission: EU-US Privacy Shield.

In addition, our employees and officers will be able to access emails and our IT systems whilst outside the EEA, in the course of their employment. This does mean that your personal data is accessible whilst outside the EU, however, we have assessed the risk and ensured adequate safeguards are in place, including the following:

• Secure email with password

• Password protected and encrypted IT systems

• IT security measures

• Training of our employees on data protection

• Robust policies and procedures

• Obligations in our contracts with employees

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. We make sure that appropriate security measures are in place to protect your personal data from being accidently lost, used or accessed in any unauthorised way, altered or disclosed. Measures are also in place to discover any breaches and to enable us to notify the ICO.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, and/or reporting requirements. We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:

• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms. Pseudonymised data is still personal data however, and we will treat it as such.

Our current retention notice is available upon request by contacting

  info@thryvetalent.com 

Accuracy of data

We do the following to try to ensure our data is accurate:

• our site enables you to manage your data and to review whether the details we hold about you are accurate
• prior to making an introduction of a candidate for a potential engagement with one of our clients we check that we have accurate information about you
• we keep in touch with you, so you can let us know of changes to your personal data

Your rights

Under certain circumstances, the GDPR provides you with the following rights in relation to data protection:

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes by checking certain boxes on the forms we use to collect your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal information to you or to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office (ICO). The ICO can be contacted through this link: https://ico.org.uk/concerns/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Access to information

You have the right to access personal data held about you. We also encourage you to contact us to ensure your data is accurate and complete. A subject access request should be submitted to dataprotection@thryvetalent.com. No fee will apply for access to your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you:

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond:

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to our privacy notice and your duty to inform us of changes

This version was last updated on 03/02/2021. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, social media accounts and affiliates. 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 policies. We encourage you to please check these policies before you visit or submit any personal data to these websites.