Privacy Policy | Closr Talent

closr TALENT (“we”, “us”, “Closr Talent”), or any subsidiary, associated or holding company, is dedicated to protecting any personal data of our clients, candidates and users of this website under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We take the privacy of personal data very seriously and therefore have a number of safeguards in place to protect your personal information. Our general principle is to consider “how would we like our own personal data to be treated?” This is our starting point that drives all our policies and procedures.

By using this website you agree that we may hold personal information that is within our legitimate interest, to assist in the recruitment process, including but not limited to your name, contact details, email address and employment details from your CV.

We may also request further information to progress an application, including references, criminal convictions, bank account details, right to work documentation, along with information regarding the type of work you are looking for.

Personal information, including bank account details and right to work information, will only be accessible to a limited number of Closr Talent employees.

When you register your CV with Closr Talent it will be made available to our consultants; prospective employers or other third parties such as specific software providers; professional bodies through an audit process; or law enforcement agencies.

Should you register your CV with us for a specific vacancy and are not successful, we will retain your details and look for alternative work. We will continue to look for work on your behalf and disclose your personal information to other clients unless you request otherwise.

In subscribing to job alert emails, you are required to provide a valid email address. We will keep you informed of the latest news and jobs as per the initial information you provided upon registration.

To unsubscribe from our website, amend your account or update your details, please email us at hello@closrtalent.co.uk.

1. Who we are

This website is operated by closr TALENT, a company registered in England & Wales.

We are not required to appoint a Data Protection Officer. However, correspondence on any data protection matters should be addressed to us at hello@closrtalent.co.uk.

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003. We collect the personal data of the following types of people to allow us to undertake our business:

Prospective and placed candidates for permanent or contract roles
Prospective and live client contacts
Supplier contacts who support our services
Employees, consultants and workers

We collect information about you to carry out our core business and related activities.

2. Information you give to us or we collect about you

This is information about you that you give us by filling in our forms or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our site, submit your CV, subscribe to job alerts, apply for a vacancy, or report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate email address, phone number, financial information, compliance documentation, references verifying your qualifications and experience and your right to work in the UK, curriculum vitae, photographic ID, links to your professional profiles available in the public domain (e.g. LinkedIn, GitHub, portfolio or corporate website), disability information, health information, criminal convictions, ethnic origin and date of birth, where relevant to a specific role or legal requirement.

We ask candidates and clients not to submit unnecessary sensitive/special-category personal data through free-text fields on this website unless it is specifically requested and relevant to an application.

3. Information we obtain from other sources

We may obtain information about you from other sources, such as LinkedIn, corporate websites, job board websites, online CV libraries, business cards and personal recommendations. We review the data protection policies and consent processes of our suppliers to help ensure they are compliant with UK GDPR.

4. Purposes of the processing and our legal basis

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into with you, and to provide you with the information, products and services that you request from us, or that we think will be of interest to you because they are relevant to your career or organisation.
To provide you with information about other services we offer that are similar to those you have already used, been provided with, or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of permanent or contract engagement in cybersecurity and technology roles. Our service also extends to supporting individuals throughout their career and supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, and also performance of a contract, legal obligations and consent for some specific uses of data.

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation, or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation if we are legally required to process information relating to you to fulfil our legal obligations.

We will, in some circumstances, rely on consent for particular uses of your data, and you will be asked for your express consent where legally required.

5. Our legitimate business interests

As a recruitment business, we introduce candidates to clients for permanent employment or contract placements. The exchange of personal data of our candidates and client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop our business, we need to record the personal data of prospective candidates and client contacts.

6. Consent

Should we want or need to rely on consent to lawfully process your data, we will request your consent orally, by email, by signing a form, or via an online process for the specific activity we require consent for, and record your response on our system. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to that particular processing at any time.

7. Disclosure of your information inside and outside the UK/EEA

We may share your personal information with selected third parties, both inside and outside the UK and European Economic Area (EEA), for the purposes of our recruitment services, including:

Clients, for the purpose of introducing candidates to them
Candidates, for the purpose of arranging interviews and engagements
Clients, business partners, suppliers and sub-contractors, for the performance and compliance obligations of any contract we enter into with them or you
Our payroll and timesheet providers
HMRC, the Department for Work and Pensions, or other government organisations required by law
Background, reference and right-to-work check providers
Our website hosting and IT service providers
Our professional advisers and auditors

We may also disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Closr Talent or substantially all of its assets are acquired by a third party, in which case personal data held about our customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of Closr Talent, our customers, or others.

The lawful basis for third-party processing will include:

Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
Satisfaction of their contractual obligations to us as our data processor
For the purpose of a contract in place or in contemplation
To fulfil their legal obligations

8. Where we store and process your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and/or the European Economic Area (“EEA”). It may be transferred to third parties outside of the UK/EEA for the purpose of providing our recruitment services, and may also be processed by staff operating outside the UK/EEA who work for us or one of our suppliers.

We rely on our legitimate interests (and, where applicable, contractual necessity or legal obligations) as the lawful basis for processing your personal data. Where we transfer your data outside of the UK/EEA, we ensure that appropriate safeguards are in place, such as adequacy regulations or standard contractual clauses (including the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses), to protect your personal data and ensure it is treated securely and in accordance with this notice.

All information you provide to us is stored on secure servers. Any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.

9. Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests. As a general guide, we retain personal data for up to 6 years and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We do the following to try to ensure our data is accurate:

Prior to making an introduction, we check that we have accurate information about you
We keep in touch with you so you can let us know of changes to your personal data
We may segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes: the nature of the personal data; its perceived accuracy; our legal obligations; whether an interview or placement has been arranged; and our recruitment expertise and knowledge of the industry by sector and job role.

We may archive part or all of your personal data, or retain it on our financial systems, deleting all or part of it from our main Customer Relationship Management (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data onto our database unless requested to do so. Pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

10. Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you, before collecting your data, if we intend to use your data for such purposes, or if we intend to disclose your information to any third party for such purposes, and we will collect express consent from you where legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by contacting us at hello@closrtalent.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

11. Your rights

Under UK GDPR, you have the following rights:

Right to be informed – about the collection and use of your personal data.
Right of access – to your personal data and supplementary information.
Right to rectification – to have your personal data corrected.
Right to erasure – also known as the “right to be forgotten”.
Right to restrict processing – to “block” or suppress processing of your personal data.
Right to data portability – to obtain and reuse your personal data for your own purposes across different services.
Right to object – to processing of your personal data.
Right to make a complaint – to a supervisory body, which in the UK is the Information Commissioner’s Office. The ICO can be contacted through ico.org.uk/concerns.

We also encourage you to contact us to help ensure your data is accurate and complete. A subject access request, or any other request to exercise your rights, should be submitted to hello@closrtalent.co.uk. Some requests may be subject to legal retention obligations that limit immediate deletion.

12. Changes to this notice

Any changes we make to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back periodically to see any updates or changes to this notice.

13. Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to hello@closrtalent.co.uk.