Privacy Policy – Talent Works on behalf of ASSA ABLOY Residential
Introduction
Talent Works helps companies to recruit the best talent. We provide a number of recruitment related services for our clients and are working with ASSA ABLOY Residential (“Assa Abloy”) in this respect.
Whether Talent Works or Assa Abloy process your information will depend on what part of the recruitment process you are engaged with:
Talent Works will process your data for the purposes of sourcing and recruiting candidates and creating and maintaining a “talent pool” of candidates (this will be done from both our Boston and UK offices)
Assa Abloy will be involved in considering candidates, interviewing and vetting potential candidates
As such, this privacy policy sets out how Talent Works (“we”) will process the information you supply if you have applied for a position at Assa Abloy and the purposes for Assa Abloy’s processing.
Both Talent Works and Assa Abloy take data privacy seriously and are committed to protecting your personal data and respecting your right to privacy. During the course of our interaction with you, perhaps if you become a candidate for Assa Abloy, we will process certain information about you.
About Talent Works
Whilst Talent Works is a UK based business (“Talent Works UK”), and therefore are bound to comply with UK data protection law, the recruitment services provided to Assa Abloy is being carried out by employees in the US, (“Talent Works US”). However, it is possible that part of our UK team will also have access and carry out some of the processing, and as such, this processing will be covered by UK data protection law, otherwise Talent Works in the US will be governed by Commonwealth of Massachusetts law.
You can find our general privacy policy on our website: https://www.talent-works.com/privacy-policy/ otherwise our processing of recruitment data in the US and UK is covered by this privacy policy.
How to contact Talent Works
If you have any questions about how Talent Works collects and uses your information not covered in this privacy notice, or if you wish to speak to someone about Talent Works’ approach to data protection and privacy, please contact their Data Protection Officer via dataprotection@talent-works.com
How to contact Assa Abloy
If you have any questions about how Assa Abloy collects and uses your information not covered in this privacy notice, or if you wish to speak to someone about Assa Abloy’s approach to data protection and privacy, please contact their Data Protection Manager gc.privacy@assaabloy.com
Data collected and processed by Talent Works during the recruitment process
Talent Works use a number of techniques to identify and recruit individuals who they think are the best match with our client’s needs:
Online advertising and websites
We sometimes attract potential candidates using online advertising, which often redirects individuals to a website landing page, which will have a simple form to collect basic information like name, email, contact details and in some cases your resume.
If you provide your information via one of these forms, it will be stored within the website database via the data collection form, and Talent Works (in the US) will be alerted (by email) to the fact someone has submitted their information. This means your data will be stored within the website database and our employees’ email programs. We may also store your information in an application tracking system, if appropriate.
We use this information purely for the recruitment process and for considering you as a potential candidate for Assa Abloy. As part of the process for considering your interest in a role with Assa Abloy, we will review your application, ask you for more information (e.g. for a copy of your resume) and screen you application against a set of requirements set out by Assa Abloy. Once we have considered these details, if appropriate we will share your information with Assa Abloy so they can consider you further, and in some cases, then carry out further processing (as set out below).
Recruitment outreach
We may contact you directly, utilising certain information that is available online, typically via LinkedIn. We will identify you from the profile information you provide and then contact you to see if you would be interested in discussing the opportunity further.
At this point, we will only be processing your online profile information for the purposes of reaching out to you. If you are interested, we will then collect more information to consider you for the opportunity, such as your contact details, CV, etc. and store this information in our applicant tracking system.
If you are interested in a role, then we will collect further information from you, such as your DOB, nationality, contact details, resume, etc. It is lawful for us to collect and process this information, because you have indicated you are interested in a role, and we need to use your information to help us process your application and assess your suitability for the role you have applied for.
We will process and store this information in our applicant tracking system and if appropriate share it with Assa Abloy, but it will be clear to you if we will be doing this.
As part of the application process, we will typically collect and process the following data about you:
Personal details; name and address
Professional details; your resume, qualifications, relevant experience and skills and any professional memberships.
We may also collect information from a number of other sources, including:
from applications forms
careers site and jobs boards
social media
We will never collect more information from you than we need to fulfil our role and to comply with our legal obligations in relation to your application. Please note that the information we request is required in order to process your application and without it, we will not be able to consider your application. We shall not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data or sensitive personal data that you provide to us.
We collect and process your personal data as part of the application process for the following purposes:
To consider your suitability for any opportunities
To confirm your references and educational background
For equal opportunities monitoring
For monitoring and assessing compliance with our policies and standards
To carry out money laundering and, financial checks and for fraud and crime prevention and detection purposes
To comply with court orders and exercise and/ or defend our legal rights
As otherwise permitted by any applicable law or regulation both in the UK and the Commonwealth of Massachusetts
Data collected and processed by Assa Abloy during the recruitment process
If your application is successful, all offers of employment are subject to satisfactory interviews and pre-employment checks (such as criminal record checks, employment history references, drug testing and other checks required by Commonwealth law), which will be carried out by Assa Abloy.
Assa Abloy will typically collect and process the following data about you in order to complete these checks:
Personal details: name, address, date of birth, nationality, marital status, country of residence, social security number, medical information (if relevant)
Professional details: your resume, qualifications, relevant experience and skills and any professional memberships, employment history for referencing purposes.
Identification documentation; a photocopy of your passport, driving licence, ID card, biometric residence permits or other documentation required by local law. Copies of these documents may include a photograph of your face and shoulders.
Assa Abloy will never collect more information from you than they need to fulfil the role and to comply with their legal obligations in relation to your application. Please note that the information requested is required in order to process your application and without it, Assa Abloy will not be able to proceed.
Assa Abloy collect and process your personal data as part of the application process for the following purposes:
To consider your suitability for any opportunities
To confirm your references and educational background
For equal opportunities monitoring
For monitoring and assessing compliance with our policies and standards
To carry out money laundering or financial checks and for fraud and crime prevention and detection purposes
To comply with court orders and exercise and/ or defend our legal rights
As otherwise permitted by any applicable US Federal and Commonwealth of Massachusetts law and regulation.
Sharing personal data with third parties
As we will be recruiting for Assa Abloy, if we believe you are a suitable match for Assa Abloy’s requirements, we will need to share the information we have collected about you with them, otherwise we will be unable to further your application.
Apart from sharing with Assa Abloy, we do not and will not sell, rent or trade your personal data. We will only disclose your personal data in the ways set out in this privacy notice and in the following circumstances:
To other financial institutions or regulatory bodies with whom information is shared for money laundering checks, and other fraud and crime prevention purposes
To any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request
Third party processors
We use a number of third-party services for the purposes of effectively running our business and providing our services to our clients (e.g. an Application Tracking System).
In all cases where we are using a third-party service or company, which requires us to share your data, we will only provide the minimal amount of information for the purposes of delivering the service to us and to meet our requirements.
We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with data protection, maintaining adequate security of your data and ensuring they apply adequate data protection principles to the processing of the data we supply. We also make sure a legally binding contract (sometimes called a Data Processing Agreement or DPA) is also in place to protect your data.
Storing your personal data
If you are unsuccessful in your application details of your application, including any personal information will be retained for a period of 6 months before being destroyed. If we identify that you may be suitable for future opportunities, we have been asked by Assa Abloy to create a “talent pool” which means we will keep your details for up to 2 years and will contact you if a suitable role becomes available but will seek your consent before doing so.
If you would prefer us not to store your information for future opportunities, please let us know during the application process or you can contact us at any time on the details above.
At any time that Assa Abloy process your data they will use our Application Tracking System as well as their own systems.
Your rights
Whilst we will primarily be recruiting for positions in California, as we set out above, some processing activity will be carried out in the UK. As Talent Works in the UK are governed by UK data protection legislation, where applicable you will be able to exercise your rights according to UK data protection legislation. Specifically:
The right of access to the data Talent Works stores and processes about you
The right to have any incorrect information about you corrected
The right to ask us, if applicable, to delete your data
The right, if applicable, to restrict the processing of your data
The right to request a machine readable export of the data we have collected from you
The right to object to our processing of your data, including the right to withdraw consent where we were required to ask you for consent to process your data
Rights to restrict any automated processing where the outcome would have legal implications, and rights to limit profiling
If you would like to exercise these rights, or if you have any questions, please send an email to: dataprotection@talent-works.com or alternatively you can write to us at: Talent Works, Century House, 1 The Lakes, Northampton, NN4 7HD.
However, if you wish to exercise your Commonwealth of Massachusetts rights under applicable privacy legislation, should they apply to Assa Abloy processing of your data you should consult Assa Abloy’s privacy policy (and/or send an email to or write to our Data Protection Officer). If you wish to contact Talent Works US, please send an email to: dataprotection@talent-works.com
Complaints
If you feel this privacy notice or Talent Works or Assa Abloy’s main privacy policies, do not go far enough in explaining how your personal data will be used, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to dataprotection@talent-works.com or gc.privacy@assaabloy.com accordingly.
If you want to make a complaint about the way we or Assa Abloy have processed your personal information, we’d rather you brought it to us in the first instance, but of course you can contact the Information Commissioner’s Office in their capacity as the statutory body that oversees data protection law in the UK – https://ico.org.uk/make-a-complaint/ or if your complaint relates to processing your data in the US, you can contact the Office of Civil Rights, US Department of Health and Human Services - https://www.hhs.gov/ocr/about-us/contact-us/index.html
Changes to this privacy policy
We or Assa Abloy may change or update elements of this privacy policy from time to time or as required by law. The most current version of this privacy policy can be requested from Talent Works by contacting dataprotection@talent-works.com or from Assa Abloy by contacting gc.privacy@assaabloy.com.
The version number and date released will always be listed below:
Version number: 1.0 Date released: 20th June 2023