Aldem Talent Ltd (“we”, “our”, “us”) is committed to protecting the privacy and security of your personal information.
This Privacy Policy outlines how we collect, use, and protect personal information about you during and after your working relationship with us, in compliance with the General Data Protection Regulation (GDPR). It applies to all employees, workers, contractors, candidates, and individuals at clients or potential clients of ours.
Aldem Talent Ltd is a “data controller.” This means we are responsible for deciding how we hold and use personal information about you. We are required by law to provide you with the information contained in this Privacy Policy.
This notice applies to current and former employees, workers, contractors, candidates, and individuals at clients or potential clients of ours in respect of whom we hold personal data. This notice does not form part of any contract of employment, contract to provide services, or any other contract. We may update this notice at any time.
It is essential that you read this notice, along with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so you are fully aware of how and why we are using your information.
Data Protection Principles
We will comply with data protection law. This requires that the personal information we hold about you must be:
- Used lawfully, fairly, and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up-to-date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The Kind of Information We Hold About You
Personal data, or personal information, 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). There are “special categories” of more sensitive personal data that require a higher level of protection.
Depending on the circumstances, we may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and email addresses
- Date of birth
- Gender
- Marital status and dependents
- Next of kin and emergency contact information
- National Insurance number
- Bank account details, payroll records, and tax status information
- Salary, annual leave, pension, and benefits information
- Start date(s) of job roles
- Location of employment or workplace
- Copy of identity documents, such as passport, driving licence, and utility bills
- Recruitment information (including copies of right-to-work documentation, references, and other information included in a CV or cover letter or as part of the application process)
- Employment records (including job titles, work history, working hours, training records, and professional memberships)
- Salary/payments history
- Performance information
- Disciplinary and grievance information
- CCTV footage and other information obtained through electronic means such as telephone recordings, email usage data, internet usage data, and swipe card records
- Information about your use of our information and communications systems
- Photographs
We may also collect, store, and use the following “special categories” of more sensitive personal information:
- Information about your health relevant to your work, including, for example, any medical condition, health, and sickness records.
- Information about criminal convictions and offences as part of the recruitment process.
How We Collect Your Personal Information
We may collect personal information about employees, workers, contractors, candidates, and individuals at clients or potential clients of ours in several ways, including through the application and recruitment process, either directly from candidates or sometimes from another employment agency, employment business, or background check provider. We may also collect information from third parties, including former employers, credit reference agencies, or other background check agencies. Individuals at clients may provide us with their contact details during discussions about our services.
We may also collect personal data that is publicly available on websites such as job boards, LinkedIn, or similar recruitment-related websites. We may use third-party applications that source their data from publicly available websites. Additional personal information may also be collected during job-related activities throughout your time working with us or when you undertake a placement.
How We Use Your Personal Information
We will only use your personal information when the law allows us to. Most commonly, we may use your personal information in the following circumstances:
- Where we are taking steps at your request before entering into a contract.
- Where we need to perform a contract that we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where it is necessary to protect your vital interests or those of another person.
- Where it is needed in the public interest or for official purposes.
Situations in Which We May Use Your Personal Information
We may need the categories of information in the section “The Kind of Information We Hold About You” for the reasons set out above in “How We Use Your Personal Information”. Primarily, this will be where we are taking steps at your request before entering into a contract, to perform a contract we have entered into with you (or your employer or a company related to you), and in some cases, to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
If You Fail to Provide Personal Information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as ensuring the health and safety of our workers).
Change of Purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. We may process your personal information without your knowledge or consent where this is required or permitted by law.
Data Sharing
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and treat it in accordance with the law. We may transfer your personal information outside the EU, and if we do, you can expect a similar degree of protection in respect of your personal information.
Why Might You Share My Personal Information with Third Parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so.
Which Third-Party Service Providers Process My Personal Information?
“Third parties” include third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services, and recruitment services.
How Secure Is My Information with Third-Party Service Providers and Other Entities in Our Group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring Information Outside the EU
We may transfer the personal information we collect about you to countries outside the EU, including [India, if applicable], where there may not be an adequacy decision by the European Commission regarding that country’s level of protection for personal information. However, we will ensure that your personal information receives an adequate level of protection by implementing appropriate measures, such as legally binding contracts governed by English Law, requiring compliance with UK data protection laws.
Data Security
We have implemented measures to protect the security of your information, including backing up and protecting the integrity of our electronic communications and data storage systems. Third parties may only process your personal information on our instructions and where they have agreed to treat the information confidentially and keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They may only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data Retention
How Long Will You Use My Information For?
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. When determining the appropriate retention period for personal data, we consider:
- The amount, nature, and sensitivity of the data.
- The potential risk of harm from unauthorised use or disclosure.
- The purposes for processing the data and whether those purposes can be achieved through other means.
- Applicable legal requirements.
In some cases, we may anonymise your personal information so that it can no longer be associated with you. If your relationship with Aldem Talent Ltd ends—whether as an employee, worker, contractor, candidate, or client—we will retain and securely destroy your personal information according to applicable laws and regulations.
Rights of Access, Correction, Erasure, and Restriction
Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed of any changes during your relationship with us.
Your Rights in Connection with Personal Information
Under certain circumstances, by law, you have the right to:
- Request Access: Receive a copy of the personal information we hold about you and verify that we are processing it lawfully.
- Request Correction: Have any incomplete or inaccurate information corrected.
- Request Erasure: Ask us to delete or remove personal information where there is no good reason for us to continue processing it. You may also request erasure if you have exercised your right to object to processing.
- Object to Processing: Object to processing of your personal information where we rely on a legitimate interest (or those of a third party) and something about your situation makes you want to object. You also have the right to object to direct marketing.
- Request Restriction of Processing: Ask us to suspend processing, for example, if you want us to verify the accuracy or reason for processing.
- Request Transfer: Request the transfer of your personal information to another party.
If you wish to review, verify, correct, or request erasure of your personal data, object to its processing, or request a transfer, please contact us.
No Fee Usually Required
You will not need to pay a fee to access your personal information or exercise your other rights. However, if your request is unfounded or excessive, we may charge a reasonable fee or refuse to comply.
What We May Need from You
We may need specific information from you to confirm your identity and ensure your right to access the data (or exercise any other rights). This is a security measure to ensure that personal information is not disclosed to anyone who does not have the right to receive it.
Right to Withdraw Consent
In cases where you have provided consent for specific processing of your personal data, you have the right to withdraw that consent at any time. To withdraw your consent, please contact us. Once we have received notification, we will cease processing your information for the purpose or purposes you initially agreed to, unless we have another legitimate basis to do so under the law.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this notice or how we handle your personal information, please contact the DPO. You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to This Privacy Notice
We reserve the right to update this privacy notice at any time. We will provide a new notice if we make substantial changes. You may also be notified in other ways about how we process your personal information.
Contact Us
If you have any questions about this privacy notice or wish to exercise any of your rights, please contact us at:
