Privacy Policy

The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

We collect your personal data from your application to a member of the Kia Authorised Dealers and Repairer network for the purposes of your application to the role of ‘Kia Genius’ only. Further details of these authorised dealers and repairers is available from this link: https://www.kia.com/uk/utility/find-a-dealer/#/step-1

The Company must have a legal basis for processing your personal data. For the purposes of your application, we will only use your personal data in accordance with the terms of the following statement.

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of assessing your application for the role of ‘Kia Genius’. The legal bases we rely upon to offer these services to you are:

Your explicit consent to assess your application to be considered as a Kia Genius.

Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data.

b. Categories of data

The Company has collected the following personal data on you:

Personal data:

Name
Contact details, including telephone number, email address and postal address
Experience, training and qualifications

c. Recipient/s of data

The Company will process your personal data with the following recipients:

Kia Motors UK – to review your application and make recommendations with regards to recruitment
Members of the Kia Authorised Dealers and Repairer network
The Recruitment and Employment Confederation (REC) for the purposes of internal audits and investigations carried out on the Company to ensure that the Company is complying with all relevant laws and obligations.

d. Statutory/contractual requirement

Your personal data is required by a contractual requirement between ourselves and Kia Motors UK Limited to enable your application to be assessed, and a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

You will not be able to proceed any further in the recruitment process to be considered for the role of ‘Kia Genius’

2. Overseas Transfers

The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of reviewing your application. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

3. Data retention

The Company will retain your personal data only for as long as is necessary and for the purposes of assessing your application and conducting an interview where relevant. Different laws require us to keep different data for different periods of time. The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

Where the Company has obtained your consent to process your personal and sensitive data (name, date of birth, contact details including postal address, telephone number, email address, experience, training and qualifications, CV, skype address), we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

4. Your rights

Please be aware that you have the following data protection rights:

The right to be informed about the personal data the Company processes on you;
The right of access to the personal data the Company processes on you;

The right to rectification of your personal data;
The right to erasure of your personal data in certain circumstances;
The right to restrict processing of your personal data;
The right to data portability in certain circumstances;
The right to object to the processing of your personal data that was based on a public or legitimate interest;
The right not to be subjected to automated decision making and profiling; and
The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data, you have the right to withdraw that consent at any time by contacting Hannah Marsh, Business Support Manager by email at hannah@talentgateway.net, by phone on 01883 585 003 or in writing to Talent Gateway, 27 Godstone Road, Old Oxted, Surrey, RH8 9JS.

5. Source of the personal data

The Company sourced your personal data by the following means:

Your application through a job board, including CV-library, Reed, Indeed, and Monster
Your direct application through the Kia Genius / Talent Gateway ‘microsite’.

This information did not come from a publicly accessible source

6. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Hannah Marsh, Business Support Manager by email at hannah@talentgateway.net, by phone on 01883 585 003 or in writing to Talent Gateway, 27 Godstone Road, Old Oxted, Surrey, RH8 9JS.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

Retention Policy

Company:	Talent Gateway (‘the company’)	Data Controller:	Hannah Marsh / Rob Jupp
Policy No.	009RP	Review Due:	February 2021
Policy Name:	Retention Policy	Last Review:	February 2020
Version:	01	Reviewed By:	Hannah Marsh

All businesses must keep personnel and financial records in order to run their business efficiently and to comply with statutory requirements. The type of record will determine the length of time the record must be kept for. As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.

The Company will retain your personal data only for as long as is necessary and in line with data protection laws. All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.

The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z3150694.

Destroying Data

Destroying or disposing of personal data counts as processing. Therefore care should be taken in the disposal of any personal data to ensure that it is appropriate. Such material should be shredded or stored as confidential waste awaiting safe destruction. Records are also deleted from our computer systems, MS Dynamics and Recruitee.

Please refer to the table below for how long we keep documents.

Table of Retention of Documents

Document Type	How long we are required to keep it for
Work-seeker records including application form/CV, ID checks, terms of engagement (see also below), details of assignments, opt-out notices and interview notes. Hirer records including client details, terms of business (see below), assignment/vacancy details.	The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We will then delete all record of the files after one year.
Terms of business with clients	Regulations provide 6 years in order to deal with any civil action in the form of contractual claim (Limitation Act 1980). Terms of business are kept for 6 years.
Annual leave records	2 years from the time they were created
Annual appraisal/assessment records	2 years from the time they were created
References	Regulations require references to be kept for 1 year following the introduction or supply of a workseeker to a client. We do not hold information on references as this is handled by the client directly or managed by our sub-contractor Cataphract Limited.
Records held relating to right to work in the UK	2 years after employment or engagement has ended – must not be alterable. We no longer hold evidence on Right to Work in the UK as this is managed through our sub-contractor Cataphract Limited.
Sickness records – statutory sick pay	3 years from the end of the tax year to which it relates
Statutory maternity, paternity, adoption pay	3 years from the end of the tax year to which it relates
Pensions auto-enrolment (including autoenrolment date, joining date, opt in and opt out notices, contributions paid)	6 years except for opt out notices which should be kept for 4 years.
Statutory maternity, paternity, adoption pay	3 years from the end of the tax year to which it relates
VAT	6 years
Company accounts	6 years
Payroll information	3 years from the end of the tax year