The websites and webpages under www.thetalententerprise.com and our assessment and survey platform know as Lighthouse
under www.tte-lighthouse.com , www.tte-lighthouse.ae and www.tte-lighthouse-sa.com and the services provided on these pages are being offered to you by:
Company Name: The Talent Enterprise Holding Limited and Its Subsidiaries (jointly known as The Talent Enterprise)
Board of Directors: David Jones, Radhika Punshi and Gauri Gupta
Registration Details: Abu Dhabi, UAE
The Talent Enterprise and its subsidiaries respects your rights to privacy. We are committed to protecting your rights and to providing transparency in respect to our data management and security policies and procedures. This document sets forth how we will use your data and personal information provided to us directly by you, by your current employer, past employer, potential employer, educational institution, a governmental authority our strategic partners or any other organisation as part of our commitment to protecting and respecting your personal information.
The data that we collect from you or receive about you may include personal information provided:
The data and personal information received by The Talent Enterprise may be shared directly by you (known as “Participant” or Participants), your current employer, your past employer, your potential employer, your educational institution, a governmental authority (all collectively known as “Client” or “Clients”), our strategic partners (known as “Partner” or “Partners”) or any other organisation (known as “Third Party” or “Third Parties”). In some cases, we may also receive payment data such as financial or credit card information if you buy our goods and services directly through our website or related platforms.
Your “data” and “personal information” includes other similar terms under applicable privacy laws such as “personal data” and “personally identifiable information”. In general, “data” refers to your responses to the questionnaires, surveys and assessments that you respond to on the Lighthouse platform. Your “personal information” includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable with a particular individual, i.e. a Participant or Participants.
It is assumed that in the case that your data is shared with us by our Clients, Partners or Third Parties, they have gained the necessary consent or are otherwise legally permitted or required to disclose your personal information to The Talent Enterprise. The Talent Enterprise is not liable for any personal Participant data shared with us that has not been directly collected by us on our website, on the Lighthouse platform or related portals.
The Talent Enterprise acts as Data Controllers with respect to personal information about you that we receive from you and / or from our Clients, Partners or Third Parties. We may also act as a Data Processor of your personal information in specific situations, in which case we will process personal information only under the instructions of our clients. In some cases, your current employer, your past employer, your potential employer, your educational institution, a governmental authority or a Partner or Third Party may also be Data Controller in which case you should contact them directly if you want to exercise a right over data for which they are Data Controller.
Further Details on Data Collection Through our Website
Further Details on Data Collection Through Lighthouse
The survey and assessment data collected on Lighthouse may be in various forms, including personal information such as your name, your email id, your photograph, your career background information, your experience and qualifications etc. as determined jointly by The Talent Enterprise as well as our Clients or Partners. At times, you may need to share personal data which may be considered as sensitive. As an example, you may inform us about a health issue, special need or reasonable adjustments which may need to be made in order for you to complete the assessment.
The assessment data collected on the Lighthouse platform includes your responses to various psychometric tests and other questionnaires, such as personality and strengths assessments, career assessments, cognitive ability tests, motives and values assessments, wellbeing surveys as well as observable competency data such as your responses to our assessment activities, such as case studies, role plays, situational judgement tests, video interviews etc. through our proprietary Talent Discovery Centres® (also known as assessment centres) or Talent Learning Centres® (also known as development centres). All of the assessment data collected on Lighthouse is ‘self-report’, i.e. based on your own responses to our questionnaires, tests and assessments.
For our wellbeing projects, we may collect additional wellbeing data such as your sleep patterns, your levels of physical activity, your nutrition and other personal and / or sensitive data around your physical and mental health from yourselves or from our Clients, Partners and / or Third Parties, on behalf of our Clients or Partners. This data may be shared with our Clients, Partners or Third Parties as per stringent confidentiality guidelines, as per the agreed project requirements and as communicated to you prior to the start of the specific project.
In some cases, we may ask you to enable your camera to capture images or videos of you for identification purposes for some of our assessments or when we conduct assessments for some clients such as video interviewing. These images or videos may be provided to clients requesting that you complete the assessment. In the event we request that you enable your camera during your participation in an assessment, this will be required for you to proceed.
360 and Multi-Rater Feedback Data
The 360 and multi-rater feedback data shared on the Lighthouse platform typically includes your responses to competency-based feedback, as well as responses from other raters or evaluators, such as peers, direct reports, line managers and other stakeholders.
Organisational Survey Data
This data includes your responses to organisational questionnaires and surveys such as employee engagement surveys, culture surveys, digital readiness surveys etc. These surveys are typically completed by you as well as by your colleagues and other employees and stakeholders within the organisation.
Use of Data
Information received by The Talent Enterprise on our website, our company social media pages as well as any related portals or platforms controlled or managed by The Talent Enterprise may be used to:
Information received by The Talent Enterprise on our assessment and survey platform, Lighthouse as well as any related portals or platforms controlled or managed by The Talent Enterprise may be used as below.
We will use your personal information, your assessment and results data, such as your personality test scores, your ability test scores, your Talent Discovery Centres® or your Talent Learning Centre® feedback etc. as well as data provided by our Clients, Partners or Third Parties on their behalf.
Please note that the assessment and results data shared would typically not include your ‘raw’ data or ‘actual’ responses, but your ‘normed’ or ‘interpretative’ data which has been analysed, scored or interpreted by The Talent Enterprise on the Lighthouse platform, any related portals or platforms controlled or managed by us, by third party test publishers, as well as by The Talent Enterprise employees, affiliates and / or experts.
This is in order for your data to be represented and interpreted most accurately and objectively as per the Code of Good Practice for Psychological Testing of the British Psychological Society (BPS) as well as with The Talent Enterprise’s Guidelines for the Ethical Use of Assessments.
Below are the ways in which your data may be used:
360 and Multi-Rater Feedback Data
Organisational Survey Data
Other Purposes for Use of Data
We commit to retaining personal information, including assessment and results data, individual and organisational reports for 18 months, after which we remove all personal information from our database, unless different terms have been agreed with our Clients or Partners.
Any research data retained thereafter (in order to produce statistics of the type described in our technical product manuals, e.g. psychometric norms and validity data no longer constitutes personal data as it is anonymised and aggregated on our systems prior to research use, at which point no individual is identified or identifiable from such data. We may also retain your personal information longer where necessary to commence or defend legal claims, and to comply with our regulatory obligations (including record retention obligations).
This also means, that we will not be able to provide any additional information about any of our Participants, whether as employees, potential employees, students or beneficiaries after 18 months. Any additional information, assessment and results data and reports requested about a Participant after 18 months will require the Participant to re-take the assessments.
Legal Basis for Processing Personal Information (EEA users only)
If you are accessing our website, Lighthouse or any related platforms or portals from the EEA, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, or where we need the personal and / or sensitive information in order to meet our performance and / or contractual obligations to you, or from our Clients, Partners or Third Parties who ask us to process your personal data on their behalf because you are their employee, potential employee, student or a related beneficiary.
Under EEA, UK and similar data protection laws, The Talent Enterprise must have a legal basis to process your personal information. In most cases, the legal basis will be one of the following:
All our Clients, who may be your current employer, your past employer, your potential employer, your educational institution or governmental organisation, as well as our Partners and related affiliates must ensure all of their team members involved in the access, analysis, or interpretation of your assessment data, results and reports has been suitably trained and accredited at the appropriate level to do so.
Disclosure of Your Personal Information, Assessment and Results Data
In addition to disclosing your personal information, your assessment and results data in order to meet our performance and / or contractual obligations to our Clients, Partners or Third Parties, we may disclose your data for the below purposes on an exceptional basis.
International Data Transfers
Due to the global nature of our business, we may need to appoint external parties to process data containing information about you on our behalf as a Data Processor, or store such information in, or transfer it to persons located in, countries outside of the European Economic Area (“EEA”). These countries may not have data protection laws equivalent to those which are in force in the EEA to protect your information. Where we transfer your information to such external data processors and/or third parties outside of the EEA and/or process your information outside the EEA, we shall try to ensure that they provide sufficient guarantees in respect of the technical and organisational security measures and take reasonable steps to ensure their compliance with those measures in order to ensure your information is adequately protected in accordance with applicable data protection laws. However, privacy laws in these countries may not provide protections equivalent to those of your country of residence. Your data may also be processed by employees, staff, partners or third parties operating outside EEA who may work for us, our partners or other affiliates. The Talent Enterprise is not liable for any significant or serious breaches or violations directly or indirectly caused by external or third parties, which are outside the control of The Talent Enterprise.
We have listed the rights you have over your personal information and how you can use them below. Please note that your consent is given voluntarily by you and you may amend, change or withdraw such consent at any time.
Your rights are subject to exemptions in applicable law and will only apply to certain types of information or processing. The Talent Enterprise shall not be responsible for or subject to any liability resulting from any change to your potential or continued employment status that may result from either your taking of the assessment(s) or your decision to withdraw your consent to the processing of the data you provide.
Your current employer, past employer, potential employer, your educational institution, a governmental authority may also be Data Controller in some cases, so you should contact them directly if you want to exercise a right over data for which they are Data Controller.
When The Talent Enterprise is the Data Controller, your rights are as below:
Please note that we may need to retain certain information for recordkeeping purposes and / or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
To exercise your rights, please contact us using the contact information below. Please note that we may not always be able to fully address your request. As an example, if it impacts our legal, contractual or performance obligations, if it impacts the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
You also have a right to make a complaint to a Supervisory Authority in your local country or jurisdiction.
Where your current employer, past employer, potential employer, your educational institution, a governmental authority or a Partner or Third Party is the Data Controller, you can contact the regulator in the location where they are based.
All credit/debit card details and personally identifiable financial information will not be stored, sold, shared, rented or leased to any Third Parties. The Talent Enterprise will never pass your financial details to any third parties. The Talent Enterprise takes appropriate steps to ensure data privacy and security including through the operation of a variety of hardware and software methodologies. However, we cannot guarantee the security of any financial information that is disclosed online through our website, www.thetalententerprise.com, or any related platforms or portals. The Talent Enterprise is not responsible for the privacy policies Third Party processors, portals or websites to which it links. If you provide any information to such Third Parties, such as payment gateways, different rules regarding the collection and use of your personal information may apply. You should contact these Third Parties directly if you have any questions about their use of the information that they collect.
Change to Data Privacy Policies and Our Terms and Conditions
How to Contact Us
You may also contact us at firstname.lastname@example.org regarding any questions or concerns about our use of your personal information and / or if you wish to find out more or exercise your data protection rights.
We respond to all requests we receive from individuals at the above address (email@example.com) wishing to exercise their data protection rights in accordance with applicable data protection laws within 78 hours on working days.