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This is the privacy policy of Sankofa Talent
This policy explains how we process personal data within our businesses delivering recruitment and talent management services, including how it affects our website: www.sankofatalent.com
We are Digital Flow SL t/a Sankofa Talent (“Sankofa Talent Solutions” or “we”, “us”) is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).
We keep this Privacy Policy under regular review and update it from time to time.
This policy was last updated in September 2022. Please review this policy periodically for any changes.
This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates.
It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
We provide executive recruitment and talent management services (“our services”) to a range of clients throughout the world. Details of our services can be found elsewhere on this website or those listed above. This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.
Additionally, this policy will apply to you if you have subscribed to receive information about our services or any of our marketing materials.
For the purposes of this policy:
Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.
We collect information from candidates directly when you upload your CV or resume to our candidate portal or when you send this to us via email. We also collect information from you when you speak with a Sankofa Talent Solutions employee.
CANDIDATE DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and social security number (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
CLIENT DATA: If you are a Sankofa Talent Solutions customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: finding Candidates who are the right fit for you or your organisation or talent management services or notifying you of content published by Sankofa Talent Solutions which is likely to be relevant and useful to you.
SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS AND DEPENDANTS: In order to provide Candidates with suitable employment opportunities safely and securely., to provide for every eventuality for them and our Staff, and to allow Staff to access certain benefits or employment rights, we need some basic background information. We ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
CANDIDATE DATA: There are two main ways in which we collect your personal data:
>1. Directly from you; and
>2. From third parties.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
CLIENT DATA: There are two main ways in which we collect your personal data:
>1 Directly from you; and
>2 From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
SUPPLIER DATA: We collect your personal data during the course of our work with you.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS AND DEPENDANTS: We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.
WEBSITE USERS: We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser.
CANDIDATE
The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
We use the personal data we collect from you for a number of purposes:
Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result, you may receive further direct correspondence from them.
Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme.
For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
Improving the service we offer. For example, you may be asked to complete one of our online satisfaction surveys.
For marketing purposes to send you information on our services, white papers, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
CLIENT
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve: (i) identifying Candidates who we think will be the right fit for you or your organisation (ii) talent management services. The more information we have, the more bespoke we can make our service.
SUPPLIER
The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
SOURCE AND REFEREE
We will use source and referee data to perform our services, in particular, to enable us to obtain your opinions on a candidate.
We may also use this information to enable us to market our services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our services.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS AND DEPENDANTS
We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff to allow that Staff member to access certain benefits or employment rights.
WEBSITE USERS
We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. If you are also a Candidate or Client of Sankofa Talent Solutions, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
Please note that communications to and from Sankofa Talent Solutions Staff including emails may be reviewed as part of internal or external investigations or litigation.
In all cases, we collect and process personal data about you, including your name, address, telephone number and email address.
CANDIDATE
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
We might also collect personal data from third-party databases and other public sources.
CLIENT
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
SOURCE AND REFEREE
As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
CANDIDATE DATA: We may share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.
CLIENT DATA: We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide you with talent management services. Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.
SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS AND DEPENDANTS: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
WEBSITE USERS: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.
For certain roles, we may run an advertisement to which you may respond, either electronically or via mail. Other roles may involve one of our researchers or consultants calling you to discuss the details. Then, we will either inform you verbally that we will process your personal data or send you a Data Privacy Notice. Both will direct you to this Privacy Policy.
Besides filling particular vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.
We care about protecting your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
We may also provide services to our clients in certain countries that entail the assessment and coaching of their employees. Here, depending on the specific assignment, we will either process your personal data to meet the legitimate interests pursued by the client or act on their behalf, in accordance with their instructions. If our services include any psychometric assessments or psychological tests, and we’re not acting on behalf of your employer, we will obtain your specific consent.
In some locations, we provide services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our services include any psychometric assessments or psychological tests, we will obtain your specific consent.
You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our services.
Remember, you may withdraw any consent you have previously given, at any time. Also, you have the right to ask us to stop processing any personal data and to have it erased.
In these circumstances, we reserve the right to maintain basic personal data such as your name and address. This is to ensure your personal data isn’t processed by us in the future.
Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect.
If you would like to receive one of our newsletters, we will ask you to provide us with your name, email address, job title, company name and country of residence.
When you have indicated you would like to receive newsletter(s) from us, we may send email alerts and bulletins about our services and any roles that might interest you.
You can unsubscribe from our electronic marketing messages by following the “unsubscribe” instructions included in our communications. Also, you may change your preferences and cease receiving direct marketing from us through your email account settings.
From time to time, we may contact you with updates on our services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.
If you take part in a user satisfaction survey, we may ask you to provide us with personal data, including your name, email address, and your views and opinions.
To help us run this website, and to provide executive recruitment services or talent management services in certain countries, we work closely with trusted partners with whom we need to share personal data. These partners include:
We will share information only as anticipated within this Privacy Policy and, wherever appropriate, limit disclosure to information in aggregated form, to avoid or limit identifying you personally.
Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.
We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.
Your information may also be shared with organisations located elsewhere in the world. As their privacy laws may not match your home country’s standards, we’ll only make a transfer data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.
Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country.
We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.
If you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.
Sankofa Talent Solutions is a global organisation – this is what enables us to offer the level of services that we do. In order for us to continue operating in this way, we may have to transfer or store your data internationally.
We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened.
In some jurisdictions, you may have the right to request copies of your personal data held by us. If you think any of that data is inaccurate, you may also ask us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your personal data. Also, you have the right to ask us to transfer your personal data to someone you nominate for your own purposes.
To get in touch with us about any of this, please email us at the email address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.
In certain circumstances, in countries where it is required or permitted by law, we might not be able to provide you with access to some of your personal data. Wherever possible, we will notify you of the reasons for this.
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data.
If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or Sabkofa Solutions newsletters) by clicking the unsubscribe link in the email, or by updating your preferences through our preference centre on the Sankofa Talent Solutions website (by signing into your account or entering your email address).
This Privacy Policy applies to our website too, where we process personal data within and through this website: www.sankofatalent.com
The primary purpose of our website is to provide you with information regarding the services provided by Sankofa Talent Solutions and consultants. In certain countries, you may use a site to view and apply for jobs.
In some countries, you may be able to set up a user account. You will be asked to register a username and password so you can gain secure access to your account.
We use the personal data we collect from you on our website for additional purposes such as personalising the look and feel of the website to fit the personal preferences inferred from how you’ve used the site. (See the “Analytics” and “Cookies” sections for more information.)
We may disclose or share personal data with third parties as outlined above to operate the website and provide our executive search services, as well as assessment services in certain countries. If you are concerned about these arrangements, you should not use the website and contact us to ask us not to process your personal data.
Finally, we might also use your data, to help our clients understand who is making use of our website and how their job vacancies are being viewed.
If you register an account with us, please do keep your details up to date, and notify us of any changes to your personal data. You can do this by updating your user preferences through your account login, or by contacting us using the details below.
We use analytics tools and cookies on this website to help deliver our online services, identify any service issues, improve our services, provide content tailored to users’ personal preferences, and to monitor site traffic and usage.
These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal data, to certain third-party services providers in order to obtain such services.
One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners
You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout
A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
This Policy only applies to this website. If you land on our site from other websites or move to other ones from our website, you should read their separate privacy policies.
If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.
If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at info@sankofatalent.com
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by which require protection of personal data.”
We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.
Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases.
CANDIDATE DATA:
We think it’s reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
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CLIENT DATA:
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
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SUPPLIER DATA:
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
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PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS:
If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
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CONSENT
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide to you as long as you do not actively opt-out from these communications.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
TO EXERCISE OUR RIGHTS OR CARRY OUT OUR EMPLOYMENT AND SOCIAL SECURITY LAW OBLIGATIONS
For some Candidates, and for individuals whose personal data is provided by Candidates and Staff , it will sometimes be necessary for us to process your sensitive/special category personal data. Article 9(2)(b) of the GDPR allows us to do this where the processing is “necessary for the purposes of carrying out the obligations and exercising [our or your] specific rights… in the field of employment and social security and social protection law”, as long as this is allowed by law.
We process Candidates sensitive/special category personal data for the purpose of ensuring our compliance with our equal opportunities obligations where this is in accordance with local law, (for example, for some Candidates during the course of the recruitment process). We may also process the sensitive/special category personal data of individuals connected with Candidates or Staff for other reasons, for example to allow the relevant Staff member to access certain benefits or employment rights. You can find out how we process your sensitive/special category personal data under “What Kind of Personal Information Do We Collect?” above.
to access, amend or take back the personal data that you have given to us;
if you suspect any misuse or loss of or unauthorised access to your personal information;
to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
with any comments or suggestions concerning this Privacy Policy
You can send an email to: info@sankofatalent.com
You can do this by updating your profile.
Alternatively you can email us at: info@sankofatalent.com or by clicking the unsubscribe link in any marketing e-mail we send to you.
Candidates – includes applicants for all roles advertised or promoted by Sankofa Talent Solutions, including permanent, part-time and temporary positions and freelance roles with Sankofa Talent Solutions’ Clients; as well as people who have supplied a speculative CV to Sankofa Talent Solutions not in relation to a specific job.
Clients – this category covers our customers, clients, and others to whom Sankofa Talent Solutions provides services in the course of its business.
Delete –In this day and age it is virtually impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, as we have explained to you in this Privacy Policy, sometimes we may be obliged by law or regulation, or need for risk-management reasons, to retain the ability to access certain elements of personal data. However, our commitment to you is that once your personal data reaches the end of its nominal retention period, or where we receive a valid request from you to erase it, we will put in place specific operational and Systems measures to ensure that your data is “put beyond use”. By this we mean that while the data will still technically exist on an archive system, we will ensure that it cannot be accessed by any of our operational Systems , processes or Staff. Only a very (and we mean exceptionally) small number of senior Staff , in very (and, again, we mean exceptionally) limited and carefully prescribed situations, will be able to restore your personal data so that it can be viewed for those legitimate purposes. Once we are clear that all relevant legally mandated retention periods have expired (which, for present purposes, we expect to be the period of ten years), we will go the additional final step of undertaking a “hard delete”, whereby not even that very limited number of senior Staff would be able to restore your personal data.
General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Staff – includes current and former employees engaged directly in the business of Sankofa Talent Solutions (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to Sankofa Talent Solutions (even though they are not classed as employees).
Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Sankofa Talent Solutions. In certain circumstances Sankofa Talent Solutions will sub-contract the services it provides to Clients to third party suppliers who perform services on Sankofa Talent Solutions’ behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Sankofa Talent Solutions requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
Systems – include telephone, computer, internet and Wi-Fi systems, software and portals, accounts and/or networks belonging, controlled or used by Sankofa Talent Solutions that are used to transmit, undertake and/or receive communications or are otherwise used in the course of Sankofa Talent Solutions’ business, including candidate portal software and CRM systems.
Website Users – any individual who accesses any of the Sankofa Talent Solutions websites.
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