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How we protect and use your personal information


We take the privacy of your data very seriously.  This page explains how we process and protect your data within the ClearTalents At Work application and who has access to your data. ClearTalent Limited is a company incorporated in England and Wales under company number 08142795, and with registered office at Field End Cottage, Bradley, SO24 9RY

We are registered with the Information Commissioner’s Office in the UK (the “ICO”), and our registration number is ZA192930.

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We collect and process your data on behalf of your employer.  We only collect data that is relevant to help you and your employer put in place any reasonable adjustments to help you be more comfortable and effective in the workplace. There are two types of profile used by employers. You may be assigned one or both of these types of profile; Workstation or DSE (Display Screen Equipment) profiles and Inclusion or Diversity profiles.

Workstation or DSE Profiles: Information is collected on a legal basis and will be shared with your line manager when you submit it. Your manager may request additional assistance from members of your employers HR team in which case they will also be able to see the information you have shared. Your employer will have identified specific members of the HR team that can provide this help and only they will be able to see the information you provided. In some circumstances, your employer’s HR team may engage with an external expert service provider to help identify how to provide you with the most appropriate reasonable adjustments in which case some or all of the information you provided may also be shared with them. The types of personal data we capture and how they are used is explained in more detail below.

Inclusion or Diversity profiles: Before we can collect any data from you for an Inclusion or Diversity profile, we require your consent to capture, store and process it.  When you submit your profile, you can choose whether to share it with your manager or not. If you have shared with your manager, they may request additional assistance from members of your employers HR team in which case they will also be able to see the information you have shared. Your employer will have identified specific members of the HR team that can provide this help and only they will be able to see the information you provided. In some circumstances, your employer’s HR team may engage with an external expert service provider to help identify how to provide you with the most appropriate reasonable adjustments in which case some or all of the information you provided may also be shared with them. The types of personal data we capture and how they are used is explained in more detail below.

How your information will be used

We process and use your data in the following ways:

Type of dataHow we use it
Email AddressWe only use your email address to identify you uniquely when you login and to send you specific messages related to your use of the ClearTalents At Work application.  We do not share your email address with any other organisation.
First name, Last nameWe use this to personalise emails that we send to you and to anyone in your organisation that you choose to share your profile with.  If you are a line manager and have profiles shared with you which you have not viewed or updated within a period of time set by your organisation, then your name will be shared with the designated administrators within your organisation so that they can follow up with you
Other specific information that may be required by your organisation such as location, functional area etc.:We use this to provide aggregate reporting to your organisation related to the implementation of reasonable adjustments.  We will not identify you individually in any of these reports
Information you provide related to reasonable adjustments in your workplace including any free text you enterThese will only be shared with your line manager or others in your organisation if you choose to do so by submitting your profile and will be used to identify and provide you with any appropriate and reasonable adjustments.  IF you submit your profile, then it will also be used to provide aggregate reporting to your organisation about different types of adjustments. ClearTalents also uses this data in an anonymised and aggregated form to produce statistical data about types of adjustments and to help make our application better.
Profile comments and status updatesWe collect an audit trail of changes and updates to your profile. These include comments that might be added by you, your line manager or others in your organisation that have access to your profile. This information will be visible to anyone that has access to your profile and may be used to review the history and actions that were taken during the identification and provision of any reasonable adjustments.

Who can access your data?

When you first create a profile, you are the only person that can access your data.  When you submit your profile, if it is a Workstation or DSE profile you will be required to share it with your manager. If it is an Inclusion or Diversity profile, you can choose whether you share it with your line manager or not.  If you do not share it with your manager then one or more members of your employers HR team that have been specifically identified by them will have access to the information in your profile so they can work with you to identify and reasonable adjustments you may require. If at any point you require support from ClearTalents support personnel, they may also be able to access some of your data in order to help you.

How and where is my data stored and protected?

Your data is stored in our data centre in the United Kingdom.  We also keep a backup in a separate UK location.  All of the data in our main system and the backup is stored using strong encryption.  We do not transfer your data outside the United Kingdom or share any of it with any other organisations.

What happens if I remove my consent?

You are free to remove your consent at any time.  You can do this from your “My Account” page.  Removing consent will only be available to you if you have been assigned an Inclusion or Diversity profile by your employer and will only affect information you have shared as part of that profile. If you remove your consent then you will no longer be able to modify the information in your profile but it will still be stored in the system.  For legal reasons we need to keep your data for up to 7 years.

Note that information submitted prior to you removing your consent will still be visible to anyone that had access to the information prior to you removing your consent, for example your line manager. If you wish to remove access from your line manager then you should edit and resubmit your profile without sharing it. We log the fact that you have removed your consent to protect your privacy. 

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