At Clear Talents, your privacy and data protection are taken very seriously. Below is a simple explanation of how your data is used, who can see it, and how it’s kept safe.
Who are Clear Talents?
Clear Talents is a UK-based company (registered as ClearTalent Limited, company number 08142795) and fully compliant with UK data protection laws. We’re registered with the Information Commissioner’s Office (ICO) and our registration number is ZA192930.
If you have concerns/complaints, you can always contact us first, or reach out directly to the ICO at www.ico.org.uk.
Why we collect your data
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.
Clear Talents collect your data on behalf of your employer to:
- Understand your needs at work.
- Help identify and implement workplace adjustments to support you.
- Make sure your experience at work is more comfortable and inclusive.
We only collect relevant information to do this, and you can choose what you share.
Creating and sharing your Inclusion Profile
- Before we collect any data from you, you’ll be asked to give ‘consent’ to capture, store and process it. This will happen before submitting your Inclusion Profile.
- When you submit your Inclusion profile, you can choose if you’d like to share it with your manager.
- Once you have created and submitted an inclusion profile (step two) for your reasonable adjustment consent no longer applies and all the data previously collected and stored about you will remain in our system. This data is retained to fulfil Network Rail’s obligations as an employer. Although neither you nor anyone else can alter it, tasks associated with your case can still be completed by the line manager, assessor, or administrator.
- Please refer to Network Rail’s guidance on ‘making adjustments’ to read the full privacy statement. To learn more about how ClearTalents processes and protects your data, click here.
- If your manager needs advice or guidance on your requests they may contact the Adjustments/HR team.
- Sometimes, your employer might involve an external expert to recommend adjustments—only relevant info will be shared.
How we use your information
We process and use your data in the following ways:
| Type of information | How it’s used |
|---|---|
| Email Address | To identify you when you log in and send updates. Never shared with anyone else. |
| Name | Used in emails and communications related to your profile. If you’re a manager, your name may be shared with internal admins if you haven’t reviewed profiles so they can follow this up. |
| Work details (e.g. location) | Used for anonymous reporting to your employer. You won’t be named. |
| Information about your needs/adjustments | Shared only with people you’ve chosen – Line manager, Adjustments/HR Team. Used to recommend and apply adjustments. Also helps create anonymous reports to improve services. |
| Comments and updates | An audit trail of changes and updates to your profile is recorded. Everyone who has access to your profile will see the history of comments and updates to understand what actions have been taken. |
Who can see your data?
- When you first create (but do not submit) a profile, your data can only be accessed Clear Talents and Network Rail Adjustments/HR team. However, at this stage the NR Adjustments team can only see your registration details. The information you have entered can only be seen by you, until you submit your inclusion profile.
- When you submit your inclusion profile, you can choose whether you share it with your line manager or not. You control who sees your profile.
- If you choose to share it with your line manager, they and Adjustments/HR staff can access it.
- If you choose not to share with your line manager, only Adjustments/HR staff can access it.
- Adjustments staff includes ‘A Local Adjustments Point of Contact (LAPOC)’ – A locally based extension of the specialist Adjustments Team, providing support to line managers and colleagues in implementing workplace adjustments when needed. LAPOCs have administrative access to the Adjustments Platform after completing upskilling sessions on disability inclusion, reasonable adjustments, data protection, and platform usage. They collaborate closely with the central Adjustments Team to share relevant adjustments data across their teams or areas, helping to ensure effective and inclusive workplace practices. LAPOCs do not have direct access to the Adjustments inbox.
Where your data is stored
- Your data is safely stored in the UK, with secure backups.
- Everything is protected with strong encryption, and your data is not shared outside the UK or with any third parties.
How long we keep your data?
- Your data is stored in line with Network Rail’s policies:
- While you’re employed, and
- Up to 7 years after you leave.
What happens if you leave or want to remove ‘Your data/consent?’
Stage 1 – Before you submit your profile:
- At Registration (Stage 1) you can withdraw your ‘data/consent’ anytime from your “My Account” page.
- If you want your information removed completely from Network Rail systems, contact: AdjustmentsTeam@networkrail.co.uk
Stage 2 – After you submit your profile
- At Submission (Stage 2) your profile becomes a formal record of your adjustments and you are not able to fully remove your ‘data/consent’
- If you remove your consent – this is logged to protect your privacy.
- You won’t be able to edit it unless you re-register.
- It will remain in the system for 7 years after you leave, for legal reasons.
- Any managers or HR who had access will still be able to view your submitted data.
- If you want to stop sharing your profile with someone (like your manager), you’ll need to resubmit the profile without sharing it with them.
If you have any questions, concerns, or want help with your profile, you can always reach out to your HR team or the Adjustments Team at Network Rail.