TALENT+
PRIVACY POLICY
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so, we are subject to the Data Protection Act, which applies in St. Kitts – Nevis, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms
Key terms used in this policy:
We, us, our – Camara Lee, trading as TALENT+, together with any trading name or names that may be more familiar to the customer or used from time to time.
Personal information – Any information relating to an identified or identifiable individual.
Special category personal information – Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.
Genetic and biometric data – Data concerning health, sex life or sexual orientation.
Personal information we collect about you
We may collect and use the following personal information about you:
• your name and contact information, including email address and telephone number and company details
• Information to enable us to check and verify your identity, eg. your date of birth
• your gender information, if you choose to give this to us
• location data, if you choose to give this to us
• your billing information, transaction and payment card information
• your personal or professional interests
• your professional online presence, eg. LinkedIn profile
• your contact history, purchase history and saved items
• information from accounts you link to us, eg. Facebook
• information to enable us to undertake credit or other financial checks on you
• Information about how you use our website, IT, communication and other systems
• your responses to surveys, competitions and promotions
This personal information is required to provide products and services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing products and services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
• from publicly accessible sources;
• directly from a third party, eg.
– sanctions screening providers;
– credit reference agencies;
– customer due diligence providers;
– employers and forrmer employers;
• from a third party with your consent
• from cookies on our website—for more information on our use of cookies, please see our cookie policy
• via our IT systems, eg.
– door entry systems and reception logs;
– automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
– HR software systems.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg.
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The information below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for
Our reasons:
To provide products and services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or TALENT+
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
For our legitimate interests or those of a third party, eg. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate that we operate at the highest standards
To comply with our legal and regulatory obligations
The information above does not apply to special category personal information, which we will only process with your explicit consent.
Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations save to the extent that it relates to the services we provide for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
• updating your marketing preferences on our Client or Candidate Portal
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
• clients;
• third parties we use to help deliver our products and services to you, eg. payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg. marketing agencies or website hosts;
• third parties approved by you, eg. social media sites you choose to link your account to or third party payment providers;
• credit reference agencies;
• our insurers and brokers;
• our banks.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, for accreditation and for the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside St. Kitts – Nevis. For more information, including on how we safeguard your personal information when this occurs, see below:
‘Transferring your personal information out of St Kitts – Nevis’.
How long your personal information will be kept
We will keep your personal information while you have an account with us, or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of St. Kitts – Nevis
To deliver services to you, it is sometimes necessary for us to share your personal information outside St. Kitts – Nevis, eg:
• with such of our offices outside St. Kitts – Nevis as may exist from time to time;
• with your and our service providers located outside St. Kitts – Nevis;
• if you are based outside St. Kitts – Nevis;
• where there is an international dimension to the services we are providing to you.
If you would like further information, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access – The right to be provided with a copy of your personal information (the right of access)
Rectification – The right to require us to correct any mistakes in your personal information
To be forgotten – The right to require us to delete your personal information—in certain situations
Restriction of processing – The right to require us to restrict processing of your personal information—in certain circumstances, eg. if you contest the accuracy of the data
Data portability – The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object – The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making – The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• let us have enough information to identify you (eg. your full name, address and customer or matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The Data Protection Act also gives you right to lodge a complaint with a supervisory authority, the Information Commissioner whose details have not yet been published.
Changes to this privacy policy
This privacy notice was published on June 25th 2020 and last updated on July 17th 2020.
We may change this privacy notice from time to time—when we do, we will inform you via our website.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Contact Details
Charlestown, Nevis, W.I.
+1 (869) 663-7266
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).