Introduction
At Start-Talk-Grow we are committed to ensuring that your personal information is protected and you understand how it is used. This Privacy Notice explains what personal information we collect, why we collect it, how we use it, the controls you have over your personal information and the procedures that we have in place to protect your personal information. It applies to the personal information we collect when an individual visits our Website.
We take our responsibility for the personal data we collect about you seriously, and we aim to be transparent about how we use, handle, and to whom we disclose, such information. Please read this Privacy Notice carefully to understand how we manage your personal data together with any additional specific privacy notice we may provide to you when we collect or process personal information about you, so that you are aware of how and why we are using the personal information and understand your rights in accordance with the General Data Protection Regulation ((UK) 2016/679) (“GDPR”).
In this Privacy Notice, when we refer to “Start-Talk-Grow“, “us“, “we” or “our“, we mean the Start-Talk-Grow group company or Start-Talk-Grow companies which are responsible for any personal information collected about you, and the Start-Talk-Grow companies to which you may apply.
2.Principles of Data Protection
When using the term “personal data” or “personal information” in this Privacy Notice, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.
We will comply with data protection law and principles in respect to your personal data, which means that your personal data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for lawful 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 and protected.
Our site may provide links to third party websites. Start-Talk-Grow is not responsible for the conduct of non-Start-Talk-Grow companies linked to the site and you should refer to the privacy notices of these third parties as to how they may handle your personal information.
3. Sources of Personal Data
We collect personal data about you from a variety of sources, as follows:
- The personal data is provided to us by you (e.g. when you register with us, including additional communications via email, telephone or Zoom/MSTeam/Skype).
- The personal data is collected in the normal course of our relationship with you (e.g. when we check references).
- The personal data has been made public by you (e.g. contacting Start-Talk-Grow via a social media platform).
- The personal data is collected when you visit our Website or use any features or resources available on or through the Website, some of which may be personal data.
- The personal data may be created by us, such as records of your communications with us or reports from your application interviews.
4. Personal Data Collected
The following is a summary of the types of personal data we collect on our Website/careers portal:
- Personal and contact details: title, full name, age, gender, address, telephone numbers, email address, visa and immigration status
- Career history: business activities, work history, employment roles, experience and referees, work-related social media profile details.
- Qualification, Training and Education History: Schools and universities attended, qualifications obtained, additional training obtained.
- Consents: consents, permissions, or preferences that you have specified, such as whether you wish to subscribe to receive Start-Talk-Grow updates and announcements when you agree to the terms and conditions for submitting your application for support from us.
- Interview details: interview responses, opinions of interviewers.
- Website Access Details: your computers unique identifier (e.g. IP Address), the date and time you accessed the Website, passwords to access alerts preferences.
5. Purposes and Use of Personal Data
The main purposes for using your personal information are (where applicable):
- to support and progress your applications to receive support from Start-Talk-Grow or to join us as a member.
- to improve and monitor the operation of our Website.
- to facilitate the delivery of the requested services
We use information held about you in the following ways:
- to assess your application and determine whether S-T-G is able to assist you.
- to contact you to arrange an interview or to discuss your application further.
- to inform you of similar opportunities arising at Start-Talk-Grow in the future.
- to obtain references from your referees.
- to administer our website and for internal operational purposes to make user experience more efficient (including troubleshooting) and to analyse how the systems are used.
- to enable you to participate in interactive features within our website.
- to prevent unauthorised access and modifications to systems.
- to ensure business policies are adhered to e.g. policies covering data protection
6. Legal basis for using your Personal Information
Data protection and privacy laws requires us to have a “legal basis” or “lawful ground” to collect and handle your personal information. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal justification to do this.
The following is a summary of the relevant legal bases for the purposes of the Privacy Notice:
- We need to use your personal information to take steps before entering into an agreement with you;
- Our use is necessary for the complying with our legal obligations;
- Where it is necessary for our legitimate interests (or those of a third party) as a non-for-profit organisation (to the extent that your interests and fundamental rights do not override those interests), such as:
- maintaining adequate applicant records;
- to assess suitability for a member role including contacting references for verification purposes;
- to detect and protect against fraud;
- to make sure we are following our own internal procedures so we can deliver the best services
- delivering the requested news alerts or updates to you;
- establishing, exercising or defending our legal rights in the event of a claim;
- monitoring operational efficiency of the Website;
- managing and operating our website IT systems and ensuring security of those systems;
Exemptions
Start-Talk-Grow sometimes handles personal information relying on exemptions under the applicable data protection law. Any permitted handling of personal information under such exemptions will take priority over this Privacy Notice to the extent of any inconsistency.
7. Sharing Your Personal Information With Others
We will only disclose personal information to a third party in very limited circumstances, or where we are permitted to do so by law. The third parties to whom we provide your personal data include:
- Other organisations within the Start-Talk-Grow members group, where such disclosure is necessary to provide you with our services or to manage our organisation. Full list of members can be obtained upon request.
- Start-Talk-Grow’s third party providers including information technology suppliers and infrastructure support services, law firms and other third party suppliers/partner organisations.
- Service providers which assist in sending drafting and sending requested news alerts.
- Government, regulatory and law enforcement bodies where we are required in order:
- to comply with our legal obligations;
- to exercise our legal rights (e.g. pursue or defend a claim); and
- for the prevention, detection and investigation of crime.
We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale or transfer of assets, or changing services suppliers provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.
Less commonly, we may process and share your personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Start-Talk-Grow will only share your personal data with our contracted service providers when we have established they have adequate and sufficient data protection controls and security controls in place. We also implement contractual obligations on these third parties to ensure they can only use your data to provide services to Start-Talk-Grow for the purposes listed above. The third parties cannot pass your details onto any other parties unless instructed to by Start-Talk-Grow.
8. Security of Your Personal Information
Start-Talk-Grow takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, modification, disclosure, alteration and destruction. We protect electronic data using a variety of security measures including:
- password access,
- data back-up,
- encryption,
- firewalls,
- placing confidentiality requirements on members and service providers and providing training to ensure that your personal data is handled correctly.
- destroying or permanently anonymising personal information if it is no longer needed for the purposes it was collected
9. How long do we keep your personal information?
Start-Talk-Grow will only retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise needed to comply with applicable law and internal company policies.
10. Your Legal Rights in Respect of Your Personal Information
You have legal rights in connection with personal information.Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Right to be forgotten enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it and we have no legitimate ground for retaining such information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
- Object to processing of your personal information by us or on our behalf in certain situations.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please submit your requests in writing via the contact details provided on the website.
Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request.
Withdrawing Consent
If you have requested Start-Talk-Grow to contact you regarding updates or about future membership opportunities, you may withdraw your consent to be contacted at any time. You can tell us that you no longer wish to be contacted by:
- Using the unsubscribe option included on email correspondence.
- Sending us an email via the contact details provided on the website
11. Changes to this Privacy Notice
We may amend this Privacy Notice from time to time to keep it up to date with legal requirement and the way we operate our business. This Privacy Notice was last reviewed and updated in May 2021
Please regularly check this page for the latest version of this Privacy Notice.
