Who are we?
Cogito Talent Limited (Cogito) provide services relating to Recruitment, Employer Brand, Learning & Development and Market Intelligence services to clients which enable organisations to make evidence-based decisions.
Purpose of this policy
This privacy notice aims to give you information on how Cogito collects and processes your personal data.
It is important that you read this privacy notice 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 notice supplements the other notices and is not intended to override them.
This policy is made pursuant to the Data Protection Act 2018 (“DPA 2018”) and the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”).
How do we obtain your personal data?
The following are the different sources we may collect personal data about you from:
Directly from you: This is information you provide while applying for jobs (either in writing or through other communications) or by you otherwise contacting Cogito.
From an agent/third party acting on your behalf: e.g. an agency supplying Cogito.
Through publicly available sources: We collect data from a variety of publicly available sources, typically, but not limited to the following: LinkedIn; Company websites; online Job Boards, Other online sources – annual reports, online articles, etc.
By Reference or word of mouth: For example, you may be recommended by a friend, a former employer, a former colleague or a present employer.
How do we use your personal data?
We’re here to help broker great matches between candidates and clients, and we will use your Personal Information solely for that purpose. As a recruitment business, we will collect and use your Personal Information to provide you with information regarding suitable employment opportunities and career-related information, and to otherwise provide you with requested information or services. In the context of our business activities the Personal Information we will collect and use is likely to include contact details (email, phone, address), employment experience / skills, educational history, salary information and future requirements / expectations together with any other information contained in your CV.
We may also gather and process data for employer brand research, other market research, salary surveys and benchmarking. This is not sensitive personal data. We process the data for our legitimate interests in understanding market trends and benchmarks for different clients, positions and industries. We have undertaken a Legitimate Interests Assessment to demonstrate this. We anonymise or pseudonymise the information if it is capable of identifying an individual.
By accepting the Terms set out here, you authorise us to use your Personal Information to send you email and/or SMS messages or marketing materials by post regarding our services, including employment information. You may opt out of receiving such messages at any time through the unsubscribe link at the foot of any message, or by contacting us at firstname.lastname@example.org.
By accepting the Terms set out here, you authorise us to use your Personal Information to send you email or contact you in relation to marketing information, reports and other business services. You may opt out of receiving such messages at any time through the unsubscribe link at the foot of any message, or by contacting us at email@example.com.
Client or Third Party
If you are a Client or other Third Party, we may use information held about you in the following ways:
- to provide you with information or services that you request
- to provide you with information which we feel may be of interest you
- to meet any of our obligations under any applicable laws or regulations;
- to carry out our contractual obligations between you and ourselves
- to notify you about changes to any of our services or business;
- for service reviews and market research purposes;
- to help us establish, exercise or defend legal claims;
You may change your marketing preferences at any time by contacting us at
Who do we share your data with?
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks. It is likely that we will need to share your data with some or all of the following (but only where necessary): Our clients, agents, servants and contractors. For example, we may ask a supplier to provide us with services.
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 contractual agreements.
How long do we keep your data for?
We understand our legal responsibility to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
Accordingly, we have a data retention policy and run routine data cleanses to remove data that we no longer have a legitimate business interest in maintaining. The amount of time we keep your data varies by the type of data. The criteria we use to determine whether we should retain your personal data includes:
- The nature of the personal data
- Its perceived accuracy
- Our legal obligations
- Whether an interview or placement has been arranged
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data.
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.
How do we transfer your data internationally?
In some rare instances, we may need to transfer your data internationally (e.g for the purpose of a global recruitment assignment or other services in which the client has an international prescence). On the occasion that your information is transferred internationally, this will always be in compliance with Chapter 5 of the GDPR regulations (Regulation (EU) 2016/679 of the European Parliament and of the Council) or with your explicit consent. In all cases, your information will be treated in compliance with UK GDPR laws.
The legal basis for Processing your data?
In the course of providing services to clients (such as recruitment, candidate experience surveys, employer brand monitoring etc) we rely on legitimate business interests to process your personal data to carry out work finding services for you, to introduce candidates to our clients for permanent employment, temporary worker placements or independent professional contracts and to carry out pre engagement and pre-employment screening services (except where we are required to obtain explicit consent to carry out a check). The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process. Legitimate Interests means the interests of the Company in conducting and managing our recruitment & research business.
When we process your personal information, we make sure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will 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).
We will ask for your explicit consent to pass your personal data to a client for consideration for permanent employment or temporary assignment. We will request your consent orally, by email or by an online process. Should we want or need to rely on consent for other processing activities, we will request consent orally, by email or by an online process for the specific activity we require consent for.
We may ask you for some ethnicity and diversity information to support our own or a client’s equal opportunities monitoring. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Providing this information is entirely voluntary and will not adversely affect your employment or engagement. It will be used for statistical analysis and equality monitoring only. We are required to comply with the Equality Act 2010 and therefore have a legitimate interest in understanding the composition of our workforce. Clients have the same obligations and rely on us as their recruitment partner to support them in meeting those obligations. If we ask you to provide diversity data which requires your explicit consent to processing, we will always ask for your consent first.
Subject Access to information & How to Contact Us
The UK GDPR and the DPA 2018 give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. If you wish to view, correct or remove any of your Personal Information that we hold, or if you have any other questions in connection with the processing of your Personal Information, please contact the Data Controller by email at: firstname.lastname@example.org or by post; Cogito Talent Limited, 53 Queen Charlotte St, Bristol, BS1 4HQ. We reserve the right to take reasonable steps to confirm your identity before making any disclosure of information, which we will do within a reasonable timeframe.