Privacy policy.
devlin talent Privacy Policy
This policy sets out the basis on which any personal data is collected, including how is it collected and processed, who has access to it and what are your rights with respect to any of your data that devlin talent processes.
Definitions
devlin talent Ltd trades as devlin talent and furthermore may be referred to as “devlin talent”.
Any mention of “Data” in this policy will refer to personal data in particular, meaning any information relating to a natural person (known as a “data subject”). This can include, among others: name, location, ID numbers, email addresses, as well as online identifiers relating to a data subject.
“Processing” of data means any action relating to collection, alteration, storing, retrieving, adapting, using, disclosing as well as erasing and destroying any data. This includes both automated and manual processing, as per the GDPR (see below).
The General Data Protection Regulation (“GDPR”), (EU) 2016/679, is a regulation which came into effect on 25th May 2018. It aims to give more control to individuals with respect to their personal data and to provide a stricter framework within which commercial organisations can operate within the EU.
What data about you is being collected?
devlin talent only collects essential personal identification information for contacting people, such as first and last name, email address and phone number. We might process certain business-related information such as the business name, job function or business address. We will never collect data belonging to special categories of personal data.
What is the legal justification for processing my data?
Under the General Data Protection Regulation, there are six different bases for legal justification for processing personal data. devlin talent’s lawful basis for processing your personal data is mostly based on the Legitimate Interests, where we believe that our services are of interest to you and your business. We will also rely on the Lawful Basis of Consent when you clearly consent to us processing your personal data for a specific purpose; or on the Legal Obligation via which our processing of your data is necessary to fulfil any legal obligations we might have.
Given the fact that devlin talent partially relies on the Legitimate Interests Legal Basis, it has performed the Legitimate Interest Assessment (LIA), as advised by the Information Commissioner’s Office (ICO).
Direct marketing to the data subjects in devlin talent’s database is necessary in order to promote devlin talent to relevant individuals and organisations. This could not in turn be achieved without processing the necessary contact details of the individuals. devlin talent filters data subjects that it may contact according to their job function, business organization and personal data purely within the context of business environment. Based on this, it is deemed that these data subjects would reasonably expect such processing of their data. It is also believed it is in their legitimate interests to be sent correspondence from devlin talent that is relevant to them in their professional capacity. The rights and freedoms of these data subjects are not overridden by devlin talent’s correspondence with them and there is no way in which any data subject would be harmed as a result of devlin talent processing their data.
As per the Information Commissioner’s Office guidance, devlin talent can confirm that:
We have checked that Legitimate Interests is the most appropriate basis for devlin talent processing personal data
We understand our responsibility to protect the individual’s interests
We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
We have identified the relevant legitimate interests
We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
We have performed a balancing test, and are confident that the individual’s interests do not override those legitimate interests
We only use individuals’ data in ways they would reasonably expect
We are not using people’s data in ways they would find intrusive or which could cause them harm
We do not process children’s data
We have considered safeguards to reduce the impact where possible
We offer an opt-out
Our LIA did not identify a significant privacy impact
We keep our LIA under review, and repeat it if circumstances change
We include information about our legitimate interests in our privacy information
Who processes your data?
Any data collected by devlin talent is only ever processed by devlin talent and the data is not transferred internationally outside of the UK, save for if it is requested by authorities outside of the UK for legal purposes. We do not share data we have collected with any other organisations or individuals.
How do we collect your data?
Most of the data we collect is provided directly by you when you contact us through our website, via email or by phone. However, we might also procure data in other ways, based on the “Legitimate Interests” lawful basis.
Any data we collect will have been obtained in one of the following ways:
You have shared your contact details with our team via any of e-mail, social media or in personal communication, with the express purpose of receiving information from devlin talent
You have voluntarily signed up to our newsletter, completed a customer survey or provided feedback on any of our online channels or via email
You have previously made contact with a member of deviln talent
You have willingly given us your contact details at an event or when signing up to attend a deviln talent event
One of our employees has found your business or personal contact details online, believing our services would be of interest to you, based upon the information you have provided online and these aligning with our customer profile
How will we use your data?
deviln talent collects your data so that we can email you with updates on deviln talent products and services that we believe will be of interest to you in your professional capacity, as well as to share some pieces that we have written on topics which are relevant to you.
If you have provided us with your contact details in order to receive marketing, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please email our Data Protection Officer at rob@devlintalent.com
How do we store your data?
deviln talent securely stores your data on an online remote storage system, i.e. the cloud, provided by Microsoft. deviln talent will keep your personal data for two years. Once this period has expired, we will delete your data from our databases.
What are your data protection rights?
deviln talent would like to make sure you are fully aware of all of your data protection rights. Under the GDPR, every user is entitled to the following:
The right to access – You have the right to submit a request to devlin talent for copies of your personal data
The right to rectification – You have the right to request that devlin talent correct any information you believe is inaccurate or incomplete
The right to erasure – You have the right to request that devlin talent erase your personal data where there is no good reason and legal obligation for us to continue processing it
The right to restrict processing – You have the right to request that devlin talent restrict the processing of your personal data, under certain conditions
The right to object to processing – You have the right to object to devlin talent’s processing of your personal data, under certain conditions
The right to data portability – You have the right to request that devlin talent transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request regarding your data, we have one month to respond to you. If you would like to exercise any of these rights, please get in touch with our Data Protection Officer by either:
Calling us at: +44 7885 293 509
Or writing to us: rob@devlintalent.com
To find out more about your data subject rights, visit: https://gdpr-info.eu/chapter-3/
What are Cookies and how do we use them?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit https://allaboutcookies.org
devlin talent uses cookies in a range of ways to improve your experience on our website, including anonymous amalgamated reports of website traffic and usage. We do not collect any personal data through Cookies.
What types of cookies do we use?
There are multiple different types of cookies, however, our website uses:
Functionality – devlin talent uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Analytics – devlin talent uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device and location.
How do I manage cookies?
You can set your browser to not accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Changes to our privacy policy
devlin talent regularly reviews its privacy policy and puts any updates on this web page. This privacy policy was last updated on 08/03/2021.
How to contact us?
If you have any questions about devlin talent’s privacy policy, the data we hold on you, or you would like to exercise any of your data subject rights, please do not hesitate to contact us.
Email our Data Protection Officer Calling us at: +44 7885 293 509
Or writing to us: rob@devlintalent.com