Privacy Policy
Pinnova Talent Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your personal information. Pinnova Talent’s core business activity is recruitment, we assist individuals in finding work with our hirer clients, whether this is directly or using a third party, we assist hirers in introducing or supplying the staff that they require. We also recruit staff to work for us to provide our recruitment services.
The EU General Data Protection Regulation (GDPR) replaces The Data Protection Act 1998. It is designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organisations approach data privacy. It aims to protect the rights of individuals, to ensure their personal data remains private and secure. It provides individuals with several rights, including the right to access information and correct any errors.
Section 1
Applies to individuals whom wish to use or are using our recruitment services or those looking for a role to work with Pinnova Talent.
The personal data we collect or receive includes the following as applicable:
Name
Address
Email and other contact details
Date of birth
Job history
Educational history, qualifications & skills
Visa and other right to work or identity information
Passport
Bank details
National insurance and tax
Next of kin and family details
Contact details of referees
Personal information relating to hobbies, interests and pastimes
Information contained in references and pre-employment checks from third parties
Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
We may obtain your personal data from the following sources (please note that this list is not exclusive):
You (e.g. a Curriculum Vitae, application or registration form)
A client
Other candidates
Online jobsites
Marketing databases
The public domain
Social Media
At interview
Conversations on the telephone or video conferencing (which may be recorded)
Notes following a conversation or meeting
Our websites and software applications
Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.
The processing of your personal information may include:
Collecting and storing your personal data, whether in manual or electronic files
Notifying you of potential roles or opportunities
Assessing and reviewing your suitability for job roles
Introducing and/or supplying you to actual or potential Clients
Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and payroll
Sending information to third parties with whom we have or intend to enter into arrangements which are related to our recruitment services
Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
To market our services
Retaining a record of our dealings
Establishing quality, training and compliance with our obligations and best practice
For the purposes of backing up information on our computer systems
Why we process your personal data:
In order to provide our services, we may enter into a contract with you and/or a third party. In order to enter into a contract, we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part, and we shall process your data as is necessary for the purpose of those obligations.
Compliance with legal obligations:
We must comply with several statutory provisions when providing our services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which requires us to:
Verify your identity
Assess your suitability for an external job role
Maintain records for specific periods
Where we engage a person to work for us (directly or to supply to a client), there are other statutory obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.
Our legitimate interests:
In providing our services, we will carry out the processing of personal data which is necessary for the purpose of our legitimate interests, which include:
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
establishing compliance with contractual obligations with Clients or suppliers
addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
protecting our reputation
maintaining a backup of our system, solely for the purpose of being able to restore the system to a point in the event of a system failure or security breach
evaluating quality and compliance including compliance with this Privacy Notice
determining staff training and system requirements
Using your personal data to:
assess suitability and contact you regarding potential opportunities and/or our services
collate market information or trends including providing analysis to potential or actual Clients
source potential opportunities or roles as part of our recruitment services
personalise your experience and our offering
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
Consent to our processing of your data:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from a third-party source is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless necessary However, to the extent that you do provide us with any sensitive personal data, such data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our services. This will be for one or more of the following reasons:
You have explicitly consented to the processing
For the purpose of our assessment of your suitability for job roles or working capacity
Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
Individuals, hirers and other third parties necessary for the provision of our Recruitment Services
Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include
outsourced payroll providers
IT support
storage service providers including cloud
background screening providers
Legal and professional advisers
Insurers
Section 2
Applies to where you are an individual working for a third party with whom we do business with.
We may collect your personal data in the course of our dealings, and this may include the following:
Your contact information, full name, job role, contact telephone number and email
Your statements and opinions about candidates and/or other personnel e.g. a reference
Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions
Your marketing preferences
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
You, including where you have provided us with your contact details or other information for the purposes of using our services
Staff or other representatives of the organisation you represent
Candidates
Marketing databases
Social media
The public domain
Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
Notes following a conversation, with you or others, or meetings you attend
How we will use your personal data:
We will process your personal data in the context of our dealings with the third party for whom you work and as part of our services. This may include:
Collecting and storing your personal data, in manual or electronic files
Using the data to communicate with you
Sending information to third parties with whom we have or intend to enter into arrangements
Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for
Collating market or sector specific information and providing the same to our clients
Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
Retaining records of our dealings with you and the organisation whom you represent
Establishing quality, training and compliance with our obligations and best practice
Our legitimate interests (carrying on the commercial activity of our services):
In providing our recruitment services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
Using your personal data:
to contact you regarding our Recruitment Services
to assess suitability of Candidates and roles, referencing etc…
to collate market information or trends including providing analysis to potential or actual Clients
as otherwise necessary to provide our services and/or to meet our obligations towards either the party whom you represent, other clients or suppliers
to personalise your experience and our offering, whether via our website or otherwise
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
establishing compliance with contractual obligations with Clients or suppliers
addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
protecting our reputation
maintaining a backup of our system, solely for the purpose of being able to restore the system to a point in the event of a system failure or security breach
evaluating quality and compliance including compliance with this Privacy Notice
determining staff training and system requirements
Consent
We may process your personal data on the basis that you have consented to us doing so, for example, if you have provided your contact details in order that we may use these to provide you with details of our services.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us, we shall discard it. Where we consider that information may be of use to us in pursuance of the provision of our services, any processing will be in accordance with this Privacy Notice.
Who we share personal data with:
We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
Candidates and other third parties necessary for the provision of our Recruitment Services
Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include
outsourced payroll providers
IT support
storage service providers including cloud providers
background screening providers
Legal and professional advisers
Insurers
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.
Section 3
Applies to all personal data - Transfer of data to other jurisdictions
In the course of the provision of our services we may transfer data to countries or international organisations outside of the EEA. Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place.
Group companies & transfer
In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.
Data Security and Confidentiality
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
Retaining your data
In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.
Changes to this Privacy Notice
This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same.
Section 4
Applies to your rights
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
Request a copy of the personal data that we hold
Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
Request that data is erased where the continued use of that data cannot be justified
Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter, where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
Request that inaccurate or incomplete data is rectified
Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third-party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights, please contact– gdpr@pinnovatalent.com.
Complaints
If you are dissatisfied with any aspect of the way in which your data is processed, please contact – info@pinnovatalent.com.
August 2025.