Effective Date: September 22, 2022
Changes to this Policy
We reserve the right to change this Policy. When we do, we will also revise the “Effective Date” at the top of this Policy. If we make material changes to the Policy, we will notify you by placing a prominent notice on our website and/or by sending you an email at the email address we have on file for you. We encourage you to periodically review this Policy to keep up to date on how we are handling your personal information.
What is Personal Information?
Personal information is information that relates to you or allows us to identify you. This includes obvious things like your name, address and telephone number but can also include less obvious things like analysis of your use of our websites. The definition of personal information can vary from one jurisdiction to another.
There are different types of personal information. The most important types for you to know about are:
- Special categories of personal information: these categories of personal information often have additional protection under data protection laws around the world. These categories include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, your genetic data and biometric data, and information concerning your sex life or sexual orientation; and
- Criminal convictions information: this is information relating to your criminal convictions and offences. Local data protection laws may restrict the way in which we can use this information when compared to, for example, your name and address.
Our Responsibility to You
We process your personal information in our capacity as a controller. This means that we are responsible for ensuring that we comply with relevant data protection laws when processing your personal information.
Please note that our clients, service providers and other third parties will have their own privacy policies. You can learn more about how your information is collected and used by relevant third parties by reviewing the privacy policies of those businesses you engage with.
Personal Information Collected
The personal information we collect about you helps us manage our relationship with you, primarily by allowing us to respond to your questions, to improve website experience, and to notify you of our services.
We also collect information throughout the employment and hiring process.
We may collect personal information directly from you, for example if you contact us to ask a question. We may also obtain personal information relating to you from other sources, including:
- Your current or past employer(s);
- Our clients and our service providers;
- Credit reference agencies;
- Anti-fraud databases, sanctions lists, court judgements and other databases;
- Government agencies and publicly accessible registers or sources of information; and
- By actively obtaining your personal information ourselves, for example through the use of website tracking devices
Which of the sources apply to you will depend on why we are collecting your personal information. Where we obtain your information from a third party, in particular your employer or our client, we may ask them to provide you with a copy of this privacy notice (or a shortened version of it) to ensure you know we are processing your information and the reasons why.
The categories of personal information we collect are detailed below. Sometimes, these activities are carried out by third parties (see “Sharing of Disclosure of Personal Data” section below).
|Category of personal information||Examples|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, address, financial, and health information|
|Commercial information||Records of products or services purchased, obtained, or considered, or other purchasing activity on our sites|
|Internet or another similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement|
|Professional or employment-related information||Current or past employment information when you submit an application to us through our site|
Use of Personal Information Collected and Legal Basis for Processing
In this section we set out in more detail the main purposes for which we use your personal information and the legal bases upon which we are using your personal information.
|Purpose||Legal basis for processing|
|To provide our Services||Our legitimate interest in using your information where this is necessary or appropriate to provide our Services|
|To respond to your requests and inquiries||Our legitimate interest in responding to your requests and inquiries|
|To improve user experiences by making our website easier to use and navigate||We have a legitimate interest in providing to you the facilities on our websites that you have requested and in understanding how our websites are used and in making our website easier to use|
|To send you marketing communications||Consent for those outside the United States, we will ask you to opt in to receiving marketing communications from us. For residents of the United States, you will be able to opt out of any such communications via a link on the message or by contacting us. Contact Us|
|To send you information regarding our Services such as information about changes to our policies and other notices and disclosures required by law||For all information – our legitimate interest in knowing the identity and background of the individuals we employ to ensure we have the appropriate staff to comply with our various legal and regulatory obligations and ethical duties|
For all information – our legitimate interest in knowing the identity and background of the individuals we employ to ensure we have the appropriate staff to comply with our various legal and regulatory obligations and ethical duties
For special category data and criminal data – employment protection
Consent and Opting out of Marketing Communications
We do not generally process your personal information based on your consent (as we can usually rely on another legal basis). Where we do process your personal information based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent please email us at email@example.com.
We provide you the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.
We may send you information regarding our Services such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature, rather than promotional.
Sharing and Disclosure of Information
We may share or disclose your information to the following categories of third parties and for the following reasons:
- To third-party service providers, agents or independent contractors who help us maintain our Services and provide other administrative services to us.
- We may share your personal information in the course of any reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- We may disclose your personal information to law enforcement, government agencies, and other related third parties, in order to comply with the law, enforce our policies, or protect our or others’ rights, property or safety.
- We may share with other third parties only with your consent or direction to do so.
We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, TALENT SHIFT cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Privacy Shield Notice
TALENT SHIFT adheres to the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce with respect to personal information that is transferred from the European Economic Area to the United States within the scope of FORVIS’s Privacy Shield certification.
To learn more, see our Privacy Shield Notice.
Profiling and Automated Decision Marking
We do not use profiling (where an electronic system uses personal information to try and predict something about you) or automated decision making (where an electronic system uses personal information to make a decision about you without human intervention).
How long do we keep your personal information?
We keep your personal information in accordance with our global data retention policy which categorizes all of the information held by us and specifies the appropriate retention period for each category of information. Those periods are based on the requirements of relevant data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, taking into account legal and regulatory requirements.
Cross border transfers of your personal information
TALENT SHIFT operates in multiple jurisdictions and your personal information may well be transferred across national boundaries.
Where we transfer your personal information across national boundaries, we will protect your personal information by ensuring that those transfers are made in compliance with all relevant data protection laws. Generally, this means where we transfer your personal information either to a TALENT SHIFT group member or to a third party that is located in a country which does not have adequate privacy protection, we will put in place a contract with the recipient of the personal information that includes the standard international data transfer contractual terms approved by the UK Information Commissioner’s Office and/or the European Commission, as applicable.
If you would like further details of how your personal information is protected when transferred from one country to another then please email us at firstname.lastname@example.org.
Under certain conditions, you may have the right to require us to:
- Provide you with further details on the use we make of your personal information;
- Provide you with a copy of the personal information we hold about you;
- Update any inaccuracies in the personal information we hold about you;
- Delete any of your personal information that we no longer have a lawful ground to use;
- Where processing is based on consent, stop that particular processing by withdrawing your consent;
- Object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
- Restrict how we use your personal information whilst a complaint is being investigated; and
- Transfer your personal information to a third party in a standardized machine-readable format.
In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
We are obliged to keep your personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information.
Your Right to Complain
If you are not satisfied with our use of your personal information or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the data protection authority that supervises our processing. In the UK, this is the UK Information Commissioner’s Office. Details of the ICO can be found at https://ico.org.uk.
Collection and Use of Information from Children
Our Services are not intended for children. We do not knowingly collect personal information from children, and none of our Services are designed to attract children. In the event that we learn that a person under the age of 13 has provided personal information to us, we will delete such personal information as soon as possible.
Our website contains links to other sites. TALENT SHIFT is not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.
How We Respond to Do-Not-Track Signals
At this time our website does not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
Residents of the European Economic Area
For individuals in the European Economic Area, please click here [link to separate document found at the end of this Policy for additional detailed disclosures regarding your Personal Data.
California Privacy Rights
Under the California Consumer Privacy Act, residents of California are provided with certain rights regarding their personal information:
- the right to “opt-out” of TALENT SHIFT’s sale of your Personal Information to any third parties;
- the right to request TALENT SHIFT to stop sharing your Personal Information with third parties;
- the right, with some exceptions, to have your Personal Information deleted from TALENT SHIFT’s possession or control;
- the right to correct inaccuracies in your Personal Information; and
- the right to receive equal service and pricing from TALENT SHIFT even if you exercise any of your privacy rights.
For all California residents, any such inquiries shall be responded to within forty-five (45) days and at no cost to you. We must verify your identity with respect to such inquiries. Depending on the nature of the Personal Information at issue, we may require additional measures or information from you as part of that verification.
California Civil Code Section 1798.83 permits California residents who use our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
We do not and will not sell personal information about California residents, as defined under California state law. We also have not done so for the last 12 months.
For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are registered user of any website where this Policy is posted. To make such a request, please Click Here. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that the law may not require or allow removal in all instances, even if requested.
To contact us to exercise any of the California rights listed above, please email us at email@example.com or call us at 1-800-367-0001.
Provisions of Services Regulations 2009
TALENT SHIFT Global Advisory (UK) Ltd is the UK firm of TALENT SHIFT, an integrated international advisory and accountancy organization. TALENT SHIFT Global Advisory (UK) Ltd is a Private Limited Company registered in England and Wales with registered Company Number 09971785 and with its registered office at 107 Cheapside, London, EC2V 6DN, United Kingdom.
Privacy Disclosures to Residents of the European Economic Area
These Disclosures apply only to our processing of personal data within the scope of the General Data Protection Regulation (“GDPR”) from one or more of the European Union Member States plus Iceland, Lichtenstein and Norway (together known as the “European Economic Area” or “EEA”).
EU Resident Rights under the GDPR
As a resident of the EU or EEA, you have certain rights with respect to the processing of your personal data, including:
Access. You have the right to know if we are processing personal data about you and, if so, to access and obtain a copy of personal data about you, as well as information relating to the processing of that data.
Correction. You have the right to have us promptly correct or update any personal data about you that is inaccurate or incomplete.
Erasure. You have the right to request deletion or erasure of your personal data in a number of circumstances as required by law, including when no longer need the personal data for the purposes for which it was collected, you have withdrawn consent or, when we are relying on legitimate interests as a legal basis, and your rights override our legitimate interests.
Portability. You have the right to obtain a copy of the personal data we hold about you in a structured machine-readable format and to have it transmitted to another controller. This right only occurs where we are relying on your consent or performance of a contract as our legal basis and the processing is carried out automatically.
Restriction of Processing. You have the right to restrict or limit the ways in which we process your personal data when you contest the accuracy of the personal data, when your data has been obtained by us unlawfully, when you have objected to our processing of the data and we are considering whether to cease processing, or when we no longer need to process the personal data.
Withdrawal of Consent. When we rely on consent as the basis for processing personal data, you have the right to withdraw your consent.
Objection. You have the right to object to our processing of your personal data when we are relying on legitimate interests as our legal basis and your rights override our legitimate interests in processing their personal data. You also have the right to object to our processing of their personal data for direct marketing purposes.
Complaint. You have the right to make a complaint about our personal data handling practices to your local Supervisory Authority.
Please call if you have any questions, because your privacy, our professional ethics and the ability to provide you with quality financial services are very important to us.
TALENT SHIFT Privacy Office
TALENT SHIFT, LLC
295 Madison Avenue, Suite 1002, 10th Floor, New York, 10017