- All references in this policy document to “personal data” or “process” are references to those terms as they are defined in –
- REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the GDPR); and/or
- the Protection of Personal Information Act of the Republic of South Africa, 2013 (Act No. 4 of 2013) (POPI)
- TALENT ANALYTICS INTERNATIONAL LTD is a company incorporated under the laws of the Republic of Mauritius and is the proprietor and/or authorised licensee (with corresponding rights to sub-license) of web-based and client network/desktop based data gathering and analytics applications and software (including those offered under the brand names; “talent print”, “talent manager”, “talent talker”, “Youlab” which are designed and coded specifically to –
- collect, collate, record, organise, structure, store, transmit, retrieve, adapt, alter and/or structure personal data from our customers and/or their employees;
- process the data collected to produce outcomes which enable our customers to implement a variety of human capital talent solutions including without limitation; performance management, leadership development, employee development, succession management, career management, mobility management, retention and reward and remuneration strategies which are mutually beneficial to them and their employees,
- In some instances our customers provide us with direct access to personal data relating to their employees without us soliciting it via our platforms. In this regard you warrant to us by using the platforms that you have consented to the disclosure of that personal data to your employer and the processing thereof by us in accordance with this terms of this policy document.
- If you want to make use of our platforms to communicate personal data to your employer you are required to register as a user and provide us with personal data which we have determined to be relevant to your employer and which we solicit from you via our platforms. We are not able to provide your employer with services contracted for by it, which are mutually beneficial to you and your employer, unless you provide us with all relevant personal data.
- NB: under no circumstances do we compel you to provide us with any personal data, you do so of your own volition. We are not responsible for any instruction by your employer. If you choose to provide us with certain information but withhold other information we reserve the right to withhold the processing of the information provided, cancel your user profile and erase all personal data held by us.
- We are committed to safeguarding the personal data of our customers and their employees and recognise the importance of processing and protecting the data in terms of the GDPR, POPI and all other regulations and laws applicable in the various global jurisdictions within which we operate.
2. Information and access to personal data
At any time that we collect personal data from you, unless we communicate otherwise by updating this section of the policy or otherwise –
- TALENT ANALYTICS INTERNATIONAL LIMITED t/a PEOPLE TREE TALENT ANALYTICS, a company incorporated in accordance with the laws of the Republic of Mauritius with the following contact details is the controller –
- we will process that data in accordance with this policy;
- the purposes of the processing for which the personal data are intended are set out in item 3 of this policy
- the legal basis for the processing is that it is processed with your consent which you may withhold before providing the personal data and which you may withdraw at any time;
- the legitimate interests pursued by us or your employer are as set out in item 3 this policy document, they overlap with the processing purposes;
- your personal data will be stored for a duration aligned to any contract which we may have in place with your employer organisation.
- you may request access to (subject to the payment of a reasonable fee where access is not possible using our platforms) and rectification or erasure of any personal data provided to us by making use of our platforms or addressing a written request to us using the contact details listed in item 2(1) below;
- you are responsible for ensuring the accuracy of all your personal data on our platforms except where you are unable to change it yourself you are require to address a request for rectification or erasure to us using the contact details listed in item 2(1) above;
- you have a right to request data portability from us in terms of the GDPR or POPI using the contact details listed in item 2(1) above;
- we will not process your personal data for any purpose other than for the processing purposes or to comply with law or court order;
- you may withdraw your consent to processing (given in terms of this policy) at any time, without affecting the lawfulness of processing based on consent before its withdrawal, in which event we will erase all your personal data, delete your platform user profile and notify your employer of your election;
- if you withdraw your consent for us to process your personal information at any time it will be honoured by us on the condition that the withdrawal will not affect the processing of your personal information –
- before the withdrawal of your consent; or
- if the processing is in compliance with an obligation imposed by law on us;
- where such processing is necessary for the proper performance of a public law duty by a public body;
- as required to finalise the performance of a contract in which you are a party; or
- as required to protect your legitimate interests or our own legitimate interests or the legitimate interests of a third party to whom the information is supplied.
- you may request that we correct, destroy or delete any of your personal data that we have processed in accordance with this policy. The personal data that you may request us to correct, destroy or delete is personal data that has been processed that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or that we are no longer authorised to retain;
- you have the right to –
- lodge a complaint with any supervisory authority or regulator including those constituted by the GDPR or POPI;
- object to the processing of any information on the grounds set out in the GDPR or POPI;
- whether the provision of personal data is neither a statutory nor contractual requirement, nor a requirement necessary to enter into a contract, it is provided by you on a voluntary basis for the purposes of us assisting your employer with its HR functions which are generally mutually beneficial to you and all its other employees;
- if you refrain from providing personal data or if you only provide certain personal data to the exclusion of other personal data, it means we will generally not be able to achieve the processing purposes, therefore we may decline to fully process that information provided;
There may be certain information which your employer provides to us independently of your disclosure using our platforms. In this regard you are referred to your employer’s personal data and privacy policies.
3. Purposes for processing
By using our platforms or by engaging with us by non-automated means or otherwise, you consent to us processing all personal data which you provide to us so that we are able to –
- provide our customers (your employer) with –
- advice on effectively and efficiently managing their human resource function including without limitation; advice on performance management, leadership development, employee development, succession management, career management, mobility opportunities, retention and reward and remuneration strategies/policies;
- the personal data collected to enable them to assess the management of your performance, your leadership development, your general career development and management, your retention and reward and your remuneration;
- improve our software, applications, methodologies, services offerings and data analytics skills and processes;
- help our agents, advisers, service providers and suppliers (our SEO agency, creative, brand, digital and media agencies) Microsoft, Google and other research agents to improve their service offering to us to the extent that this improves our service offering to your employer;
- monitor web traffic: web servers serving our platforms automatically collect information about pages you visit. This information is used for internal review, to tailor information to individual users and for traffic audits;
- perform statistical analyses in order to measure interest in the various areas of the website (for product development purposes);
- comply with all relevant laws on disclosure for crime prevention, statists, research other otherwise,
(collectively the processing purposes).
4. Types of personal information we may process
- The categories of personal data which we will process in achieving the processing purposes, include –
- your name and surname;
- your identity or passport numbers or any other number used by authorities to identify you;
- your location details including your physical address;
- your online identifiers and browser history, including cookies;
- your email address;
- information relating to your –
- employment history;
- academic qualifications;
- work related skills;
- work experience;
- strengths and weaknesses;
- employment history;
- union membership;
- philosophical beliefs;
- beliefs relating to the manner in which your employer conducts its business or how it should conduct its business;
- opinion on the competence of management and leadership within your employer’s business,
all of which is relevant to the processing purposes.
- While you consent to us processing your personal data in general you explicitly consent to us processing your personal data listed in item 4(1)(f) You furthermore acknowledge that it is necessary for processing by us on your employer’s behalf in your field of employment.
5. Processing of personal information
Personal data will be processed by us when you make use of our platforms to the extent required for us to achieve the processing purposes and for no other purpose other than where processing is required by law.
- We may place a cookie on your browser to store and sometimes track information about you.
7. Use of IP address
- An IP address is a number that is automatically assigned to a computer whenever it is connected to the Internet. We log IP addresses or the location of computers on the Internet.
8. Links to other sites
When you are using the website, you could be directed to other sites that are beyond our control. These other web sites may send their own cookies to you collect data or solicit personal information. We do not control the privacy policies of those third-party web sites.