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Ortus Talent is committed to maintaining robust privacy protections for its users. We want you to know that you can trust us with your information when you use our organisation. We are determined to do nothing that would infringe on your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it.
We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registered address is X, our registration number is 13091579 and our Data Protection Officer/Lead (DPO/DPL) is Abby Barnes. Our Data Protection Officer/Lead can be contacted at email@example.com.
Information we collect
Our Lawful Basis for processing your information
The General Data Protection Regulation (GDPR) requires all organisations that process personal data to have a Lawful Basis for doing so.
The Lawful Bases identified in the GDPR are:
1. Consent of the data subjects
2. Performance of a contract with the data subject or to take steps to enter into a contract
3. Compliance with a legal obligation
4. To protect the vital interests of a data subject or other person
5. Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
6. The legitimate interests of ourselves, or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
Examples of Legitimate Interests include:
1. Where the data subject is a client or in the service of the controller
2. Transmission within a group of undertakings for internal administrative purposes
3. Processing necessary to ensure network and information security, including preventing unauthorised access
4. Processing for direct marketing purposes, or to prevent fraud
Our Lawful Basis is all of the above and our Legitimate Interest is all of the above.
Ortus Talent will process information about your use of our website and services. The usage data may include:
1. The browser types and versions used
2. The operating system used by the accessing system
3. The website from which an accessing system reaches our website (so-called referrers)
4. The sub-websites
5. The date and time (so-called timestamp) of access to the Internet site
an Internet protocol address (IP address)
6. The Internet service provider (ISP) of the accessing system
7. The geographical location of the user
8. The page views and site navigation paths
9. The pattern of the users’ use of the service with regards to timing and frequency
of any other similar data and information that may be used in the event of attacks on our information technology systems.
Enquiry data, correspondence data and customer relationship data
Ortus Talent may process information contained in any enquiry you submit to us regarding our services and products. If a user contacts us via email or via a contact form, the personal information transmitted by the user is automatically stored while you maintain a client/candidate, unless a deletion request is submitted.
The personal information may include:
1. The user’s contact information
2. The user’s name
3. The name of the user’s employer
4. The user’s job title or role
5. The metadata associated with the communication
6. Information contained in communications between the user and Ortus Talent
We may share your personal data with:
1. Our delivery partners
2. Our legal advisors in the event of a dispute or other legal matter
3. Law enforcement officials, government authorities, or other third parties to meet our legal obligations
4. In connection with, or during negotiations of, any merger, sale of company [assets, consolidation or restructuring, financing, refinancing, or acquisition of some or all of our business by another company
The source of the usage data is Google Analytics. The usage data collected is needed to:
1. Deliver the content of our website correctly
2. Optimise the content of our website as well as any advertisement
3. Ensure the long-term viability of our information technology systems and website technology
4. Provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
We do not use automated decision-making in the processing of your personal data.
Ortus Talent may process information that you provide to us for the purpose of subscribing to our email marketing efforts.
Our emails will only be received by the user if:
1. The user has a valid email address
2. The user opts in to receive marketing.
You may opt out of receiving emails and other messages from our organisation by following the instructions in those messages.
How we use and share information
Personal data is transmitted on a voluntary basis by a user to Ortus Talent are stored for the purpose of processing or contacting the user, managing our relationships with customers, keeping records of communication with the user, and promoting our products and services to customers.
In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
Retaining and deleting your personal information
The personal information that we process for any purpose or purposes will not be kept for longer than is necessary for the expressed purpose.
We will retain your personal data as follows:
1. For as long as your data is relevant to the services we provide
2. A maximum of 5 years; or
3. Whichever is the lesser
In some instances, it is not possible for us to specify in advance the periods for which your personal information will be stored by us. In such cases, we will determine the period of retention based on legal advice.
We retain your personal data while you remain a candidate/client or for up to 5 years, whichever is the lesser. Our Retention and Disposal Policy details how long we hold data and how we dispose of it when it no longer needs to be held.
We will delete or anonymise your information at your request unless:
1. There is an unresolved issue, such as a claim or dispute
2. We are legally required to
3. There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers' safety and security
Subject Access Request (SAR)
You may request access to, correction of, or a copy of your information by contacting us at firstname.lastname@example.org.
1. Validate users
2. Remember user preferences and settings
3. Determine the frequency of accessing our content
4. Measure the effectiveness of advertising campaigns
5. Analyse site visits and trends
Your data protection rights (GDPR)
If you are a resident of the EEA or the UK, you have the following data protection rights:
1. You can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information.
2. You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt out of other forms of marketing, please contact us by emailing email@example.com.
3. Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
4. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests from individuals wishing to exercise their data protection rights per applicable data protection laws.
Links to other websites
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by email or by placing a prominent notice on our site. Significant changes will go into effect 14 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
This website is owned and operated by Ortus Talent. We are registered in the United Kingdom under registration number 13091579.
ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY
For inquiries regarding your personal data, please contact firstname.lastname@example.org
- POLICY STATEMENT
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes
various forms, such as slavery, servitude, forced and compulsory labour and human
trafficking, all of which have in common the deprivation of a person’s liberty by
another in order to exploit them for personal or commercial gain. Ortus Talent Ltd and its
subsidiaries (“We”) have a zero-tolerance approach to modern slavery and are committed
to acting ethically and with integrity in all our business dealings and relationships and
to implement and enforce effective systems and controls to ensure modern
slavery is not taking place anywhere in our own business or in any of our supply
1.2 We are also committed to ensuring there is transparency in our own business
and in our approach to tackling modern slavery throughout our supply chains,
consistent with our disclosure obligations under the Modern Slavery Act 2015. We
expect the same high standards from all of our contractors, suppliers and other
business partners, and as part of our contracting processes, we include specific
prohibitions against the use of forced, compulsory or trafficked labour, or anyone held
in slavery or servitude, whether adults or children, and we expect that our suppliers
will hold their own suppliers to the same high standards.
1.3 This policy applies to all persons working for us or on our behalf in any capacity,
including employees at all levels, directors, officers, agency workers, seconded
workers, volunteers, interns, agents, contractors, external consultants, third-party
representatives and business partners.
1.4 This policy does not form part of any employee’s contract of employment and we
may amend it at any time.
- RESPONSIBILITY FOR THE POLICY
2.1 The board of directors has overall responsibility for ensuring this policy complies
with our legal and ethical obligations, and that all those under our control comply with
2.2 The Legal and Compliance team has primary and day-to-day responsibilities for
implementing this policy, monitoring its use and effectiveness, and dealing with any
queries about it, and auditing internal control systems and procedures to ensure they
are effective in countering modern slavery.
2.3 Management at all levels is responsible for ensuring those reporting to them
understand and comply with this policy and are given adequate and regular training
on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be
improved. Comments, suggestions and queries are encouraged and should be
addressed to the Legal and Compliance team at email@example.com responsibilities.
- COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our
business or supply chains is the responsibility of all those working for us or under our
control. You are required to avoid any activity that might lead to, or suggest, a
breach of this policy.
3.3 You must notify the Legal and Compliance team as soon as possible if you
believe or suspect that a conflict with this policy has occurred, or may occur in the
3.4 You are encouraged to raise concerns about any issue or suspicion of modern
slavery in any parts of our business or supply chains of any supplier tier at the
earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur
you must report it in accordance with our Whistleblowing Policy as soon as possible.
3.6 If you are unsure about whether a particular act, the treatment of workers more
generally, or their working conditions within any tier of our supply chains constitutes
any of the various forms of modern slavery, raise it with your manager.
3.7 We aim to encourage openness and will support anyone who raises genuine
concerns in good faith under this policy, even if they turn out to be mistaken. We are
committed to ensuring no one suffers any detrimental treatment as a result of
reporting in good faith their suspicion that modern slavery of whatever form is or may
be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Legal and Compliance team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our Staff Playbook.
- COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in
its supply chains, forms part of the induction process for all individuals who work for
us, and regular training will be provided as necessary.
4.2 Our zero-tolerance approach to modern slavery in our business and supply
chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate
- BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could
result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations
working on our behalf if they breach this policy.
Environmental & Ethical Supply Chain
Ortus Talent recognises and understands the importance of protecting the environment in which we operate. We are fully committed to minimising the impact that running our business has on the environment and we encourage our clients, suppliers and other stakeholders to do the same.
Ortus Talent is aware that our business activities do not produce emissions covered by environmental protection legislation. We will comply with all relevant legislative, regulatory and other environmental requirements in order to act in a socially responsible manner and we will strive to continuously improve our environmental performance.
Ortus Talent will aim to:
- Minimise the use of natural resources;
- Minimise the generation of waste and implement/promote recycling;
- Maximise the use of e-technology to reduce paper usage throughout our operation;
- Minimise pollution and promote greener transport options;
- Consider the environmental impact of any business decisions made;
- Inform and encourage staff at all levels to act in an environmentally responsible manner, and encourage feedback from staff on improvements and feed these into the policy;
- Designate appropriate resources in order to implement, monitor and continuously improve the policy;
- Make this policy available to any interested external parties and to employees.
All staff are encouraged to take reasonable practical steps in the course of their duties, including minimising printing and disposing of waste in an environmentally friendly fashion.
Ethical Supply Chain
Our ethical supply chain policy requires that the ethical issues and social responsibility within supply chains are understood and addressed when managing business-to-business supplier relationships and through the purchasing of goods and services from our suppliers.
Upholding the principles of this policy is a shared responsibility between the Company and its suppliers. The Company expects its suppliers to assign and accept similar responsibilities and will give consideration to this in procurement decisions.
Our sustainability objective is to ensure continuous improvement in that procurement decisions are made with consideration to delivering sustainable and ethical trading.
Our ethical objective is to ensure that people in the supply chain are treated with respect and have rights with regard to employment, including the rights to freely choose employment, freedom of association, payment of a living wage, working hours that comply with national laws, equal opportunities, recognised employment relationship, freedom from intimidation and to a safe and healthy working environment.
The Company requires suppliers to comply with their National Laws in respect of; health and safety at work, employment law including minimum working age, discrimination in respect of race, gender, religion, disability and harassment and bullying etc.
We will use our purchasing power, where practicable, to influence and encourage suppliers in order to create a more reliable market for environmentally and ethically produced products and services. Environmental and social factors shall be considered in the purchasing process. Specifically, this includes considering what the product is made from, the product durability, where it is made and by whom, the efficiency of the product during use and the processes involved in its production and distribution, what the disposal requirements are, and if it can be reused or recycled.