Purpose of this privacy policy

This privacy policy explains how Kara Gibson-Coyle Ltd trading as KGC Talent (referred to as "we", "us" or "our" in this privacy policy) collects and processes your personal data. It applies, in particular, to the personal data of:

• candidates seeking roles which we are engaged on behalf of our clients to fill (“Candidates”);
• employees, directors and other staff members of our clients and suppliers;
• individuals approached to give Candidate references (“Referees”); and
• visitors to our websites at kgctalent.com and kgctalent.co.uk.

Controller
Kara Gibson-Coyle Ltd is the “data controller” responsible for the personal data we collect and hold about you as described in this privacy policy. We are registered with the ICO with registration number ZA826655.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us by using the contact form on our website.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

“Personal data” 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).

‍Candidates: We may collect, use, store and transfer the following kinds of personal data about you (together referred to as “Candidate Data” below):

• Full name, marital status, title, gender, date of birth, age;
• Passport details, identification documents and visa/right to work information;
• Contact details, including home and work addresses, telephone numbers and email addresses;
• Job title, the name of the organisation for which you work, details of your duties and responsibilities;
• Copies of CVs and references;
• Career and remuneration history;
• Education history and grades;
• Preferences regarding a new role and geographic mobility;
• Membership of professional bodies;
• Number and age of dependants;
• Personal interests and hobbies; and
• Any other information you choose to tell us.

Clients: We may collect, use, store and transfer the following kinds of personal data about employees, directors and other staff members of our clients (together referred to as “Client Data” below):

• Full name, marital status, title and gender
• Contact details, including work address, telephone number(s) and email address(es)
• Job title, the name of the organisation for which you work, details of your duties and responsibilities
• Career history and
• Any other information you choose to tell us.

Visitors to our website: We may collect, use, store and transfer the following kinds of personal data about visitors to our website (together referred to as “Website Data” below):

• Information about your browser, network, and device;
• Web pages you visited prior to coming to our website;
• Your IP address; and
• Details about your use of this website, including clicks, internal links, pages visited, scrolling, searches and timestamps.

Referees: We may collect, use, store and transfer the names, contact details, job title and employer name of Referees provided by a Candidate (together referred to as “Referee Data” below).

Suppliers: We may collect, use, store and transfer the following kinds of personal data about employees, directors and other staff members of our suppliers (together referred to as “Supplier Data” below):

• Full name, marital status, title and gender;
• Contact details, including work address, telephone number(s) and email address(es); and
• Job title and the name of the organisation for which you work.

We do not intentionally collect details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we intentionally collect any information about criminal convictions and offences. If you choose to provide any of this information to us we will assume that you have thereby given your consent to us holding this information about you.

If you fail to provide personal data

• Candidates: If you do not provide sufficient personal data we may not be able to recommend you to our clients or progress your application (for instance, if you are unable to provide evidence of your right to work in the UK).
• Employees, directors and other staff members of our clients and suppliers: If you fail to provide personal data when requested that we need to collect by law or to perform a contract with you or the organisation for which you work, we may not be able to perform such contract. We will notify you if this occurs.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data when we contact you or you contact us directly, such as by sending us your CV;
• Third parties or publicly available sources. We may obtain personal data about you from publicly available sources such as corporate websites; and
• Automated technologies or interactions. As you interact with our website, we will automatically collect Website Data in order to analyse your use of our website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookies policy for further details.

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

• It is necessary for the performance of a contract with you or to take steps at your request before entering into a contract with you;
• It is necessary for our legitimate interests (or those of a third party) in conducting and managing our business. 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;
• We need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

• Candidates: We collect and use Candidate Data in order to identify suitable candidates for positions with our clients, communicate with Candidates regarding potential roles, arrange interviews, discuss and agree the terms of engagement or employment with our clients and generally to manage our relationship. We may also use Candidate Data in order to send marketing information, such as contacting a Candidate to inform them of new job opportunities. Using Candidate Data in this way is necessary for our legitimate interests in pursuing our business, seeking new opportunities for Candidates and fulfilling our contracts with our clients. We may on occasion also need to use Candidate Data in order to comply with our legal obligations.
• Clients: We collect and use Client Data in order to fulfil the contract we have with our clients. For instance, we use Client Data to communicate with our clients. We may also send marketing information to employees, directors and staff of our clients, such as sending details of a potential Candidate who we think may be a good fit for the client’s organisation. Using Client Data in this way is necessary for our legitimate interests in pursuing our business, seeking new opportunities for Candidates and fulfilling our contracts with our clients. We may on occasion also need to use Client Data in order to comply with our legal obligations.
• Website visitors: We collect and use Website Data in order to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to analyse how you use our website. Using Website Data in this way is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud). We may on occasion also need to use Website Data in order to comply with our legal obligations.
• Referee Data: Referee Data is used to provide references for a Candidate to a client, or to put a client in touch with a Referee directly by passing on the Referee’s name and contact details to the client. Using Referee Data in this way is necessary for our legitimate interests in pursuing our business, seeking new opportunities for Candidates and fulfilling our contracts with our clients.
• Supplier Data: We use Supplier Data in order to obtain goods and services to run our business. Using Supplier Data in this way is necessary in order to perform the contracts we have with our suppliers (in the case of sole traders or partnerships), and for our legitimate interests in running our business. We may on occasion also need to use Supplier Data in order to comply with our legal obligations.

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 would like further details. 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.

We may send marketing information to you, for instance, we may send Candidate Data to clients or potential clients in order to suggest Candidates for roles with that organisation. We may also send details of new opportunities to Candidates or potential Candidates. You can ask us to stop sending you marketing messages at any time by contacting us at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

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.

We may share:

• Candidate Data with clients (with the Candidate’s consent);
• Client Data with Candidates;
• Referee Data with employees and other staff members of our clients;
• Website Data with Squarespace, our website hosting platform and analytics provider, to learn about site traffic and activity
• Personal data with our third-party service providers, including IT service providers, cloud storage providers, database/CRM providers and outsourced financial providers (such as providers of banking, invoicing, expenses and payroll services);
• Personal data with our professional advisers such as lawyers, accountants and insurers; and
• Personal data with HM Revenue & Customs, regulators and other authorities.

This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you including information about your browser, network or device and your IP address.

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 in accordance with our instructions.

If we need to transfer your personal data out of the UK (for instance, by transferring Candidate Data to one of our clients outside of the UK) we will ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The country to which your personal data is transferred has been deemed to provide an adequate level of protection for personal data by the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk); or
• We have put in place standard contractual clauses in a form approved by the European Commission or the ICO in order to give personal data the same protection it has in the UK.  

Please contact us if you require further information.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

How long will you use my personal data for?
‍
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.If we anonymise your personal data (so that it can no longer be associated with you), such as for research or statistical purposes, we may use this information indefinitely without further notice to you.

Under applicable data protection laws, you have the right to:‍

• Request a copy of the personal data we hold about you and to check that we are lawfully processing it (commonly known as a "data subject access request");
• Request correction of any incomplete or inaccurate data we hold about you;
• Request erasure or deletion of your personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Object to processing of your personal data 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 data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; 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 where 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 certain personal data to you or to a third party 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 at any time to the Information Commissioner's Office, the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance; and
• Withdraw consent. Where we are relying on your consent to process your personal data, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note that if you withdraw your consent, we may not be able to provide services to you. We will advise you if this is the case at the time you withdraw your consent.

Please contact us if you wish to exercise any of the rights set out above.

We do not carry out any automated decision-making, such as profiling, using your personal data.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 to exercise rights under data protection laws within one month. Occasionally it could 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.