INTRODUCTION

References to “us”, “we” or “our” are references to Accelerate Talent Limited, a company registered in England and Wales with company number 09576990, whose registered address is at Scale Space, 58 Wood Lane, London, W12 7RZ.

References to “you” are references to:

• you, the individual about to submit your CV and/or personal data onto our Recruitment Platform; or
• if you are a company, to your employees, officers, agents and contractors; or
• if you are a recruitment agency, to your employees, officers, agents, contractors, candidates and/or potential candidates (as the case may be),

as the recipient of our services which include certain recruitment, talent and job referral services (the “Services”).

We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you about (i) how we look after your personal data when you use the Services and (ii) your privacy rights and how the law protects you as a recipient of the Services.

This privacy policy is provided in a layered format as set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your personal data through your use of the Services, including any data you may provide through the Services.

The Services is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

CONTROLLER

The Services are provided by Accelerate Talent Limited, who is the controller of, and is responsible for, your personal data.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Full name of legal entity:
Accelerate Talent Limited

Name and/or title of DPO:
Dougie Reid

Email address:
dp@blenheimchalcot.com

Postal address:
Scale Space, 58 Wood Lane, London, W12 7RZ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on the date detailed in the header of the first page and historic versions can be obtained by contacting us.

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.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, national insurance number, DBS certificate, nationality and tax residency status.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Lifestyle Data includes education and employment details such as dates attended university and current or previous job roles and professional qualifications.
• Financial Data includes salary expectations, salary, bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of the Services you receive from us.
• Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), and any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel our Services but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We obtain data from and about you through:

• direct interactions with you or a recruitment agency acting on your behalf whether by post, phone, email or otherwise; and/or
• you or a recruitment agency uploading your CV and/or details onto our Recruitment Platform.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where we have received your consent to do so

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We are an in-house recruitment team that services the Blenheim Chalcot Ventures and each Blenheim Chalcot Venture has access to our Recruitment Platform. Therefore, when you or a recruitment agency on your behalf (where applicable), uploads your CV and/or cover letter and/or details (collectively, your “Application”) onto our Recruitment Platform, you understand, acknowledge and agree that the personal data contained within your Application will be shared with, or accessible by, each of the Blenheim Chalcot Ventures. Please note that you will not be notified further by us each time a Blenheim Chalcot Venture accesses your personal data in accordance with this Privacy Policy.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Blenheim Chalcot Ventures as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at recruitment@blenheimchalcot.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Blenheim Chalcot Ventures means other companies within the Blenheim Chalcot portfolio that act as joint controllers or processors, including without limitation Blenheim Chalcot LTF Limited, BC Foxtrot Limited, Accelerate People Limited, Accelerate Talent Limited, Accelerate Places Limited, Accelerate Digital Limited, Accelerate Business Networking Limited, Accelerate Technology Limited, Blenheim Chalcot Management Limited, Pillar Ventures Limited, BCI Management Services Limited, Liberis Limited, Avado Learning Limited, BC Arch Limited, Mortgage Power Limited, Dynamo Mortgages Limited, Agilisys Limited, Fair Way Forward Limited, BC EnglishScore Limited, BC Music Media Limited, Business Finance Technology Group Limited, Hive Learning Limited, Contentive Limited, Fospha Limited, Fuse Mobile Technologies Limited, Modulr Holdings Limited, Oakbrook Finance Limited, Salary Finance Limited, Stack Content Discovery Limited and any and all of the above entities’ parent companies, subsidiaries or group companies whether based in the UK, Jersey, Guernsey or otherwise. Furthermore, Agilisys IT Services India Private Limited & Blenheim Chalcot IT Services India Private Limited, which are based in India, also form part of the Blenheim Chalcot Ventures.

External Third Parties means:

• Service providers acting as processors based in the UK who provide support services including without limitation the service provider for our Recruitment Platform.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, US, Singapore, Australia or other jurisdictions as and when needed to perform the Services who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

RECRUITMENT PLATFORM

The information you provide to our Recruitment Platforms may be transferred to countries outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information, you consent to these transfers for the purposes specified above.

We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:

1. Greenhouse, 18 West 18th St, 11th Floor, New York, NY 10011 United States, we use this as our applicant tracking system and recruitment software. Greenhouse will hold your Application(s) and we make these Application(s) available to any of the Blenheim Chalcot Ventures.
2. HubSpot, 25 First Street, 2nd Floor Cambridge, MA 02141 United States; for the purposes as our Email distribution. Hubspot holds details about you pulled from publicly available sources such as LinkedIn. We make the information about you on Hubspot available to any of the Blenheim Chalcot Ventures.

All of our International service providers have each provided the information to demonstrate they have appropriate technical and organisational measures in place to safeguard personal data, and it shall be processed to at least the same standards as set out by the General Data Protection Regulations: Each organisation participates in The Privacy Shield framework, which is accepted by the European Commission as evidence that an adequate level of protection exists for the personal data in the country, territory, or organisation where it is being transferred, in this case, the United States.

You can obtain a copy of the safeguards and any other of Greenhouse’s data protection documentation by visiting https://www.greenhouse.io/security-and-performance, or applying via post to Greenhouse, 18 West 18th St, 11th Floor, New York, NY 10011 United States.

You can obtain a copy of the safeguards and any other of HubSpot’s data protection documentation by visiting https://www.hubspot.com, or applying via post to HubSpot, 25 First Street, 2nd Floor Cambridge, MA 02141 United States