Privacy Policy

Effective from 1st June 2022

www.easyapprenticeships.com  is operated by Easy Apprenticeships, a trading name of TalentSpa Limited (“TalentSpa”). TalentSpa is registered in England and Wales under company number 10325023. TalentSpa registered address is 1 Poultry, London, England, EC2R 8EN

We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. “Personal Information” is information that identifies you as an individual such as your name, date of birth, email address, IP address and CV.

How do we collect information from you?

We collect and use your Personal Information in accordance with this our Privacy Policy.   Please do not submit such Personal Information to us if you do not wish us to collect it.

Please be aware that we may also infer certain information about you from your expressed search preferences. We also collect from:

  • our websites (the “Websites”);
  • the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
  • cookies (“Cookies”);
  • publicly available information; and,
  • other tools and applications (our “Online Content”).

What Personal Information do we collect?

Personal Information we collect about you may include the following:

General identification and contact information: your name; address; email; IP address; telephone details; gender; marital status; family status; date and place of birth; physical attributes including photos.

Other sensitive information: trade union membership, religious beliefs, political opinions or racial or ethical origin, and criminal record.

Information enabling us to provide products and services: age, location, whether or not you hold a driving licence that enable identification of job search (for example, post code or job role).

Marketing preferences: enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.

Statistical information: aggregate statistical information about site visitors and users for internal use and for other lawful purposes e.g., Salary averages. We provide this information to customers, advertisers, suppliers and other reputable third parties. Where we provide such information, we will provide this in an anonymous format and not include any Personal Information.

Information from Apps: submit comments to the Site, participate in message boards, blogs, send us emails or any other user generated content facility.

Publicly available information in relation to professional history: educational background; employment history; skills and experience; professional licenses and affiliations; educational and professional qualifications.

What legal basis do we rely on to process your Personal Information?

Consent

On some occasions, TalentSpa processes your data with your consent. For example, we rely on consent when we send promotional material. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

The processing is necessary to fulfil a contract

TalentSpa may process your data when we need to do this to fulfil a contract with you, such as to send your CV to an employer or recruiter for a specific job application.

Legitimate Interest

TalentSpa also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights.

Our legitimate interests include:

  • ensuring the security and integrity of our Services and in ensuring that our Websites and Apps operate effectively;
  • selling and supplying goods and services to our customers;
  • protecting customers, employees and other individuals and maintaining their safety, health and welfare;
  • promoting, marketing and advertising our products and services;
  • sending promotional communications which are relevant and tailored to individual customers;
  • understanding our customers’ behaviour, activities, preferences, and needs;
  • improving existing products and services and developing new products and services;
  • handling customer contacts, queries, complaints or disputes; and,
  • fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

The processing is necessary because of a legal obligation that applies

TalentSpa may process your data to comply with our legal and regulatory obligations, e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.

Who do we share your Personal Information with?

Our group companies

We may share your personal data with certain members of our group companies which also operate online job portals. Where they have access to your personal data, they will use it only for the purposes set out in this Privacy Policy. TalentSpa will remain responsible for the management and security of jointly used Personal Information. Access to Personal Information within TalentSpa and our group of companies, is restricted to those individuals who have a need to access the information for our business purposes.

Recruiters and other agents

In the course of our business to help you search for and get a job, TalentSpa may make Personal Information available to third parties such as recruiters and other intermediaries and agents and other business partners.

Our service providers

This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

Governmental authorities and third parties involved in court action

TalentSpa may share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

Other third parties

Occasionally, we may share Personal Information with other third parties. We will always do this under contract and in accordance with your instructions.

How we use Personal Information?

We use Personal Information to do some or all of the following:

  • Communicate with you as part of our business;
  • Send you important information regarding changes to our policies, other terms and conditions, the TalentSpa and Easy Apprenticeships websites and Apps and other administrative information;
  • Provide improved quality, training and security and manage other commercial risks;
  • Carry out market research and analysis, including satisfaction surveys;
  • Provide marketing information to you (including information about other products and services offered by selected third-party partners);
  • Personalise your experience on the TalentSpa and Easy Apprenticeships Websites and Apps by presenting information and advertisements tailored to you and by providing you access to selected services of our group companies;
  • Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully;
  • Facilitate social media sharing functionality;
  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management;
  • Resolve complaints, and handle requests for data access or correction;
  • Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
  • Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

International Transfers of Personal Information

Personal Information which you supply to us is generally stored and kept inside the European Economic Area.

However, due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection. In such situations, we transfer the minimum amount of data necessary, anonymise it where possible and enter legal contracts to aim to ensure these third parties handle your Personal Information in accordance with this Privacy Policy and the European levels of data protection.

How can you manage or delete Personal Information?

When you access our website online, we may store some anonymous information about your visit which is used for statistical purposes.

Please note that TalentSpa reserves the right to remove from our database, CVs which include any content that we consider to be illegal or offensive. 

You can delete your account at any time by sending an email to our Data Protection Department (see below) with the subject line “Permanently delete my information and account”. Please do not forget to tell us who you are and send the request from your registered email address.

Security

TalentSpa is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold.

Our security measures include:

  • encryption of our services and data;
  • review our information collection, storage and processing practices, including physical security measures;
  • internal policies setting out our data security approach and training for employees.

Additional Services for Website and App

Online drives

If you enable us, we access the following Services for the limited purpose of helping us to upload or otherwise access your CV, cover letters or any other documents you provide us to assist you apply for jobs. The Services we use are:

  • Google Cloud
  • OneDrive
  • DropBox
  • Box

We will ask for your consent before using information for any other purpose.

Services provided by Group Companies

As part of our websites or apps, we may provide you access to selected services of our group companies. 

Marketing and Advertising

Your Rights

You have the following rights:

  • the right to ask what personal data that we hold about you at any time, subject to a fee specified by law;
  • the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
  • (as set out above) the right to opt out of any marketing communications that we may send you.

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

Children and minors

TalentSpa is not directed towards individuals under the age of eighteen (18), however we are aware due to the nature of some of the job offerings, those between 14 and 18 may use the Services.
Individuals under the age of thirteen (13) are expressly prohibited from using TalentSpa and IT Career Swap Websites and Apps, unless parental consent is provided, and we are notified.

Third Party Privacy Practices

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties to which the TalentSpa and Easy Apprenticeships websites and Apps link. The inclusion of a link on the Website or App does not imply endorsement of the linked site or service by us. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organisations or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organisations through or in connection with the Apps or our Social Media Pages.

Please note that although we require customers who use our services, such as employers seeking to recruit staff, to agree to use the information made available solely for recruitment-related purposes, we do not control their use of any information that they have access to as part of receiving our services. Please be aware your current employer may be a customer of TalentSpa, or a client of one of our job boards in our group of companies. 

Data Retention Policy

TalentSpa seeks to ensure that it retains only data necessary to effectively conduct its business. The need to retain data varies widely with the type of data and the purpose for which it was collected. TalentSpa strives to ensure that data is only retained for the period necessary to fulfil the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth TalentSpa’s guidelines on data retention and is to be consistently applied throughout the organization.


Scope

This policy covers all data collected by TalentSpa and stored on TalentSpa owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by UK General Data Protection Regulation (GDPR). 

 

Reasons for Data Retention

TalentSpa retains only that data that is necessary to effectively conduct its business and comply with applicable laws and regulations.


Reasons for data retention include:

  • Providing an ongoing service to the data subject (e.g., sending a newsletter, publication or ongoing program updates to an individual, ongoing training or participation in TalentSpa’s programs)
  • Compliance with applicable labour, tax and immigration laws
  • Other regulatory requirements
  • Security incident or other investigation
  • Intellectual property preservation
  • Litigation


Data Duplication

TalentSpa seeks to avoid duplication in data storage whenever possible, though there may be instances in which for programmatic or other business reasons it is necessary for data to be held in more than one place. This policy applies to all data in TalentSpa’s possession, including duplicate copies of data.


Retention Requirements

TalentSpa has set the following guidelines for retaining all personal data as defined in its data privacy policy.

 

  • Website visitor data will be retained as long as necessary to provide the service requested/initiated through the TalentSpa and IT Career Swap websites.
  • Contributor data will be retained for the year in which the individual has contributed and then for 3 Years after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.
  • Training Program participant data will be retained for the duration of the program plus any additional time required under the terms of the programs finance agreement.
  • Recruitment data, including notes on applications, will be held for 3 Years after the closing of the recruitment process.
  • Data associated with payments (for enrolled courses) will be held for 3 Years.


Data Destruction

Data destruction ensures that TalentSpa manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, TalentSpa will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to his/her supervisor and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by TalentSpa’s data protection officer in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.

 

Who to contact about your Personal Information?

The data controller responsible for your information is TalentSpa.

If you have any questions about this policy or our use of your Personal Information you can email: dataprotection@talentspa.co.uk, or write to the Data Protection Department, TalentSpa, 1 Poultry, London, England, EC2R 8EN.

If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, are available at ico.org.uk.

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please view the “Effective from” date at the top of these terms to see when it was last revised.