Privacy
Statement
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
Purpose
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.
We recommend that you read this Privacy Policy in full to ensure you are fully informed of your data privacy rights. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.
Data Collection
The data that we collect from you or receive about you may include personal information provided:
- On our website, www.thetalententerprise.com, our company social media pages as well as any related portals or platforms controlled or managed 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.
- On third party platforms as well as any related or affiliate portals that we may use on behalf of The Talent Enterprise from time to time.
- On emails, on the phone as well official and personal correspondence at events, conferences, marketing promotion campaigns, research projects etc. by employees of The Talent Enterprise, or affiliates, partners and representatives of The Talent Enterprise
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
The Talent Enterprise website (www.thetalententerprise.com) may automatically collect the following information through the use of cookies and related tools and technologies.
- General information including traffic on website, location information, Participant and efficiency metrics such as time spent on page, number of click throughs, number of repeat visits, number of downloads etc.
- In some cases, specific information including your browser type and version, time-zones, your Internet protocol address (IP address), referring website information (if any) and other related parameters.
- Information shared by you on our website such as your contact details, requirements.
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.
Assessment Data
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
Website 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:
- Contact you to understand your interest or requirements from The Talent Enterprise.
- Contact you regarding any updates or changes about our service.
- To fulfil any performance and / or contractual obligations to our Clients, Partners or Third Parties.
- Your personal information may be added to our marketing database(s), from which you can choose to opt out anytime.
- We warrant that we will never rent or sell your personal data to any organisation, affiliates or third parties.
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.
Assessment Data
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:
- To use your assessment and results data to create summary and in-depth insights and reports to authorised representatives of our Clients, including Partners or Third Parties (known as “Individual Assessment Reports”).
- With prior approval from our Clients, Partners or Third Parties, provide you with some or all of your Individual Assessment Reports and feedback. Please note that the dissemination of your assessment reports, results and feedback is the sole responsibility of our Clients or Partners. The Talent Enterprise will only provide your results based on the specific direction and requirements from our Clients or Partners. Participants taking the assessments are not guaranteed access to their individual results unless our Clients or Partners wish us to do so.
- In most cases, especially in the case of psychometric assessments such as personality tests, ability tests etc. we would compare your assessment and results data as well as data provided by our Clients, Partners or Third Parties with anonymised benchmark data to help understand how your data may compare to similar demographic or representative groups for the purposes of career fit, hiring and selection, talent identification, talent development, succession planning, talent transformation etc.
- We may also provide the authorised representatives of our Clients, including Partners or Third Parties with in-depth analysis and insights at a team, group, departmental or organisational level (known as “Organisational Strategic Insight Reports”).
- In order to meet our performance and / or contractual obligations, and to manage and administer our services, we may also provide a copy of the assessment and results data to our Clients, Partners or Third Parties for use by them for their own records or for internal human resource management purposes. This may include a technology integration with an ATS, ERP, LMS, LXP or related portal or platform or be shared manually in a safe, password protected or encrypted format.
- Your data will only be shared with authorised personnel representing our Clients, Partners of Third Parties who may be your current employer, your past employer, your potential employer, an educational institution or a governmental organisation.
- It would be the responsibility of our Clients, Partners or Third Parties to ensure that all authorised personnel 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.
- It is the responsibility of the authorised personnel representing our Clients, Partners or Third Parties to not share your data who has not been explicitly authorised without prior written approval of The Talent Enterprise.
- It would be the responsibility of our Clients, Partners or Third Parties to ensure that they use the assessment and results data to make objective and fair decisions for purposes such as career fitment, hiring and selection, talent identification, talent development, succession planning, talent transformation etc., including ensuring compliance with company policies and applicable laws and regulations.
- We warrant that we will never rent or sell your personal data to any organisation, affiliates or third parties.
360 and Multi-Rater Feedback Data
- In the case of 360 and multi-rater surveys, we are committed to protecting the privacy and anonymity of reviewers or evaluators.
- We would only share collective or group feedback for categories of reviewers such as ‘peers’, ‘direct reports’, ‘indirect reports’ etc. for 3 reviewers or more. Any data less than this is clubbed under the category of ‘other.
- This is not the case for the categories of ‘self’ and ‘line manager’ where there is only one respondent and the scores may be shared.
- In terms of individual and organisational report sharing, the same guidelines as above under the Assessment Data category would apply.
Organisational Survey Data
- In the case of organisational surveys, such as employee engagement, employee culture, digital transformation surveys, custom employer surveys etc. we are committed to protecting the privacy and anonymity of employees or survey respondents.
- In the case of organisational surveys, we would only share collective or group feedback where we have data from 5 or more employees or survey respondents. Any data less than this will be clubbed into another larger category.
- In terms of organisational report sharing, the same guidelines as above under the Assessment Data category would apply.
Other Purposes for Use of Data
- We may use your personal information, assessment and results data for research and development (R&D) purposes. Data from our assessments, surveys and diagnostic tools may be used to create norm groups, benchmarks and overall trends and insights, including analysing aspects such as gender, age and cultural background data to ensure fairness, accuracy and objectivity of results.
Data Anonymity
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:
- To comply with our legal obligations.
- With your consent. You have the right to withdraw your consent at any time by contacting us using the contact details below.
- In order to meet our legitimate interests and to fulfil our performance and / or contractual obligations to our Clients, Partners or Third Parties.
The Talent Enterprise has achieved and adheres to the data protection quality standards as specified in the international standard ISO: ISO:27001 and complies with relevant best practice outlined in the General Data Protection Regulations (GDPR) of the European Union, amongst others. Please refer to this Privacy Policy, along with the policies and guidelines of your current employer, your past employer, your potential employer, your educational institution, governmental organisation or relevant country of residence standards for further information of your data rights and obligations and how to exercise them.
The Talent Enterprise also complies with the Code of Good Practice for Psychological Testing of the British Psychological Society (BPS) as well as with our Guidelines for the Ethical Use of Assessments. This means that anyone at The Talent Enterprise or acting on behalf of The Talent Enterprise who analyses, interprets or makes decisions based on your assessment data is suitably trained to do so and has signed the relevant data protection clauses in their contract, consistent with this privacy policy.
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.
- To comply with any legal obligation, or in order to enforce any statutory requirements, or to protect our rights, property, or safety or those of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of data security and fraud protection. This may include laws outside your country of residence.
- Incase The Talent Enterprise sells our business or assets of our business in part or in full, we may disclose your personal data to the prospective buyer of the business or assets. We may also disclose your personal data to a vendor of another business or assets that The Talent Enterprise may be acquiring or to fulfil a joint venture or merger obligation. If our business or assets are acquired by a third party, any personal information, assessment data and all other information about you, and held about our Clients, Partners, Third Parties will be transferred accordingly.
- In order to facilitate the assessment process and to meet our performance obligations, information about you may also be passed to our Partners, related Third Parties including external suppliers from time to time and their respective suppliers. This may include (but not limited to) cloud hosting providers, database portals, email marketing and communication services and portals etc. as well as ATS, ERP, LMS, LXP or related portals or platforms our Clients and Partners may already be using.
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.
Your Rights
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:
- You may ask us to review, make amendments or withdraw your personal information.
- You can ask us to confirm if we are processing your personal information and, if we are, you can ask for access to that personal information as well as further details including why your data is being used and for what purposes.
- You can ask to correct your personal information held by us if you believe it is erroneous or contains omissions.
- You can ask to restrict how your personal information is used.
- 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.
- Incase of any requests, you would need to clarify what personal information you would like to have changed or removed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. We may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
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.
Payment Records
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
Our Privacy Policy and all other related terms and conditions may be changed or updated occasionally to meet new requirements and standards of privacy and to reflect our terms and conditions of sale. Therefore, you are encouraged to frequently visit these sections to be updated about the changes on the website. Modifications will be effective on the day on which they are posted.
How to Contact Us
You may also contact us at dpo@thetalententerprise.com 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 (dpo@thetalententerprise.com) wishing to exercise their data protection rights in accordance with applicable data protection laws within 78 hours on working days.
