Privacy Policy

Impact Talent Solutions, LLC and its subsidiaries respect your privacy, and we acknowledge that you have an expectation of privacy related to any personal information we collect from you and we have certain obligations with respect to the same. Impact Talent Solutions supports the various privacy laws and has procedures in place to meet the requirements of those laws.

This Privacy Policy supports our privacy principles and informs you about our practices for gathering, storing, and using the personal information of individuals who use our websites, apply for or who are employed or assigned by Impact Talent Solutions, and those who are representatives of our customers (including prospective customers), service providers, and suppliers.

We encourage you to review this information so that you may understand how we collect, use, and share your personal information.

If we change anything important about this Privacy Policy (the information we collect, how we use it, or why we use it), we will highlight those changes in the Change History section at the end of this Privacy Policy and provide a prominent link to it for a reasonable length of time following the change and prior to the change taking effect.

If you have questions, please contact the Data Protection Officer at:

E-mail: privacy@ImpactTalentSolutions.com

INFORMATION WE COLLECT

Impact Talent Solutions collects, stores, and uses personal information to provide our recruiting, employment, outsourcing and related professional services. We collect personal information about individuals who:

visit our website, are employed, assigned, or placed by Impact Talent Solutions, apply for or are considered for employment, assignment, or placement with Impact Talent Solutions, and are representatives of our customers (including prospective customers), service providers, and suppliers.

We may collect, store, and use the following categories of personal information:

Information we collect as part of the registration process, recruitment or job-matching services whether provided online, in-person, or by telephone.

Contact Information – Name, postal address, email address, and telephone number. Professional Information – Job title, department, or job responsibilities.

Resume Information – Employment and education history, language proficiencies, security clearance information, and other work-related skills, awards, and honors, membership in clubs and organizations, personal interests and activities, and information regarding your career interests and other qualifications for or desires regarding future employment opportunities, including information regarding desired compensation and benefits.

Information you provide about others – Referrals, references or information regarding your emergency contacts.

Job-related social media data – Information from and related to publicly published profiles you’ve created on job-related social media platforms and job boards (such as LinkedIn, Monster, or CareerBuilder).

Information we collect as part of the hiring and on-going employment processes.

Contact Information – Name, postal address, email address, and telephone number.

Identification Data – Social security number, social insurance number and/or driver’s license, passport, or State/Province ID number and contents.

Information we collect as part of the hiring and on-going employment processes.

Contact Information – Name, postal address, email address, and telephone number.

Identification Data – Social security number, social insurance number and/or driver’s license, passport, or State/Province ID number and contents.

Screening Data – Drug, alcohol, and criminal background checks.

Financial and Benefits Data – Tax identification number, social security number, financial or bank account information, tax-related information, next-of-kin or emergency contact information, benefits selections potentially including health insurance, retirement planning information, and disability and health-related information, and health information, including that related to a work-related claim (e.g. Workers’ Compensation Claim).

Information you provide about others – Referrals, references or information regarding your emergency contacts.

Demographic Information – Date of birth, citizenship and work authorization status, and any other identification provided to Impact Talent Solutions for application or employment purposes.

Additional demographic information – Gender, race, ethnicity, disability, veteran information, ideological views or activities, or membership in trade unions.

Biometric Data – Fingerprint identification.

Information we collect from individuals representing organizations.

Contact Information – Name, postal address, email address, website and telephone number.

Information we collect through your use of our website.

Credentials – User ID, log-in credentials, password, and/or PIN.

Location data – Your location, as provided.

Cookies and similar data – Cookies, web beacons, and other similar technologies.

Information when you communicate with us whether in person, through our website or via e-mail, over the phone, through social media, or via any other medium.

Contact Information – Name, postal address, email address, telephone number or social media account details (depending on how you choose to communicate with us).

Communications – Details of communications with us (including when it was sent, when it was received and where it was sent from (such as our website, post, telephone, e-mail, or social media)), as well as messages to you (including information that you may post on our social media platforms)

Information that we collect from third party partners, our customers, and other Impact Talent Solutions companies.

Credit Data – Credit information (i.e. credit report, credit score, etc.).

Background Data – Background screening information (i.e. address history, criminal records, MVR, etc.).

Identification Data – Identity verification (i.e. government issued identification, social security number, etc.).

Information that we collect incidentally from other sources or public sources.

Public Information – Information available in the media, social media or wider social media platforms (Facebook, Twitter, and LinkedIn), and security systems.

WHY WE USE THE INFORMATION WE COLLECT

Information we collect as part of the registration process, recruitment or job-matching services whether provided online, in-person, or by telephone.We use this information to:

create, manage, and administer an individual’s relationship with us; assess an individual’s suitability for employment and employ individuals; match candidates with potential positions; offer candidates placement at our customers; refer an individual for employment to one of our customers;

provide general work-seeking services to individuals;

meet our obligations when acting as an employer in connection with the contract of employment and other obligations which apply to us under applicable employment laws;

manage the employment relationship with an individual, including for human resources management (for example career development, training, talent management, performance management, appraisals, and disciplinary and grievance management);

meet our obligations to an individual in respect of our contract with the individual when we act as an employment agency, recruiter, hirer, outsourcing or related professional services agency;

contact individuals via regular mail, e-mail, phone, text messages, and online communication platforms about our company or job openings that match the individual’s stated preferences, qualifications, and/or profile; these communications will only come directly from Impact Talent Solutions (or agents working on behalf of Impact Talent Solutions);

maintain appropriate records for potential and/ or actual litigation or investigations concerning us or any group company or its officers; and

Information we collect as part of the hiring and on-going employment processes. We use this information to:

to meet our obligations when acting as an employer in connection with the contract of employment and other obligations which apply to us under applicable employment laws; manage the employment relationship with an individual, including for human resources management (for example career development, training, talent management, performance management, appraisals, and disciplinary and grievance management); detect or prevent any inappropriate behavior or breach of our policies, including protecting our intellectual property, confidential information, and assets; make contact in an emergency;

ensure that our (or any of our group companies) systems are used primarily for business purposes, have sufficient capacity for the needs of the business, and are protected against cybersecurity threats such as malware;

meet our obligations to an individual in respect of our contract with the individual when we act as an employment agency, recruiter, hirer, outsourcing or related professional services agency;

to maintain appropriate records for potential and/ or actual litigation or investigations concerning us or any group company or its officers; and

personalize and deliver content about our services to individuals. For example, where individuals share geolocation data with us, this will allow the individual to search for jobs or create job alerts within that geographic area. In some jurisdictions, we must process this personal data in order to comply with statutes, rules, and regulations pertaining to equal employment opportunities or to assist Impact Talent Solutions in compiling data for its equal opportunity practices and reporting, we may also ask you to provide additional information. The provision of this type of information will be voluntary, unless it is required by law, and failure to provide this information will not hinder your employment or project opportunities.

We collect and use Screening Data and Demographic Information when consistent with a legal basis and only as authorized under applicable law. Voluntary self-identification of race and ethnicity will be kept confidential and will only be used in accordance with the provisions of applicable federal laws, executive orders, and regulations, including those which require the information to be summarized and reported to the Federal Government for civil rights enforcement purposes.

We collect and use Financial and Benefits Data to administer payments to you, provide employment-related health and retirement services, and other benefits applicable to your employment.

We collect and use Biometric Data in order to limit access to certain secure locations.

We use information relating to leaves of absence to comply with employment, social security, social protection and other laws, and to record and administer sickness and maternity leave.

We use information about your physical or mental health to ensure your health and safety in the workplace and to assess your fitness to work subject to appropriate confidentiality safeguards and to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

Information we collect from individuals representing organizations. We use this information to: provide and manage staffing placement, consultancy, outsourcing, and vendor management services; develop and maintain staffing and outsourcing relationships with our customers, suppliers, and service providers. We use the information, including delivering event and marketing communications, through e-mail, telephone, text messaging, direct mail, and online communication platforms. These notifications will provide instructions on how to opt out of receiving similar e-mails or communications from the service; and improve our services and develop new services based on the preferences and behaviors of these individuals.

Information we collect through your use of our website. We use this information to: identify issues with the website or application and user’s experience of the website or application; manage and administer our IT systems; and monitor the way our website is used (including locations it is accessed from, devices it is accessed from, understanding peak usage times, and analyzing what functionality and information is most and least accessed).

Instead of having to type in your personal information, some of functionalities on our website may allow you to use third-party authentication tools such as Facebook, Twitter, and Google to populate certain fields. By authenticating through one of the social media options, you allow us to receive your personal and other information that is accessible through these tools. This information may be incorporated into your profile. For any such tool you choose to use, we encourage you to also review the tool provider’s privacy policy and any terms and conditions.

Information when you communicate with us whether in person, through our website or via e-mail, over the phone, through social media, or via any other medium. We use this information to: answer any issues or concerns; monitor communications for quality and training purposes; develop new services which is based on the information you provide; improve our services based on the information and feedback you provide and the information and feedback provided by others; personalize our service to you to take account of the information and feedback you have provided; and make necessary disclosures in response requests which we are legally required to comply with, to law enforcement or regulatory authority, body or agency, or in the defense of legal claims.

We may use personal information to permit you to participate in live social media feeds. If you choose to participate, your public username may be displayed on the sites along with your post, including, but not limited to, comments, images, and video. We may provide you with access to third-party functionality that allows you to post content to your social media account(s). Any information that you provide through use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Statement.

Information that we collect from third party partners, our customers, and other Impact Talent Solutions companies. We use this information to:

ensure that individuals are genuine and to verify the information provided to guard against fraud and other criminal activities; provide, manage, and administer our services to individuals and our customers; manage and administer our IT systems; personalize our service to you by complementing your behaviors and preferences; perform statistical analysis and research into the individuals using our services so that we can better understand our users and develop and improve our services to meet the needs and preferences of our users and our customers; and

combine this information with other types of information mentioned above to create holistic profiles of our customers which allows us to make our services more personal and tailored to each customer’s preferences and habits.

Information that we collect incidentally from other sources or public sources. We use this information to: maintain market awareness; build and maintain social media presence and branding; and provide security to our premises.

We will only use your personal information 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.

LEGITIMATE INTERESTS

As mentioned above, we can, sometimes, use your personal information where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal information is necessary to: ensure effective administration and management of your employment or engagement (including your potential employment or engagement), benefits, management of the business, and business continuity; ensure our assets are protected, kept confidential, and not used for inappropriate or unlawful purposes; prevent, detect, or investigate unauthorized use of our systems and ensure we comply with law and our policies; ensure we can contact you or your family in the case of an emergency; check you are legally entitled to work, manage performance, discipline, and promotion processes; manage training and development requirements; maintain product development and enhancement, along with effective marketing through analytics and profiling for business intelligence; deal with disputes and accidents and take legal or other professional advice; comply with another country’s laws and regulations; prevent fraud and financial crime; and ensure network and information security.

If you would like further information on our legitimate interests as applied to your personal information, please contact the Data Protection Officer.

FAILURE TO PROVIDE INFORMATION WHERE REQUIRED

Where we are requesting information from you in order to employ or engage you, or in order to place or job-match you, if you do not provide the information that we have identified as required we may be unable to properly assist with your request for employment, placement, or job-matching to be performed by Impact Talent Solutions.

RETAINING YOUR INFORMATION

We will retain your personal information for as long as is necessary to provide you with the services requested, or for other necessary purposes such as compliance with a law, regulation, or other legal authority, or as is otherwise permitted to be maintained for other legal purposes, such as audit, security, fraud prevention, or preserving and defending Impact Talent Solution’s legal rights.

Due to our various obligations for retaining records, retention periods may vary. For example, we will retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to attempt to comply with your request not to receive any future marketing communications from us. Also, we will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

We use the following criteria to determine retention periods: how long the data is needed to provide staffing and managed services and operate our business; whether there are contractual or legal obligations that exist that require us to retain the data for period of time; whether any law, statute, or regulation allows for a specific retention period; whether an individual has agreed to a longer retention period; whether the data is considered to be sensitive data, and what the expectation for retention was at the time the data was provided to us.

In all cases, we will continue to protect your personal information in accordance with the terms of this Privacy Policy. We will also routinely refresh our information to ensure we keep it up-to-date.

INFORMATION WE SHARE

Impact Talent Solutions holds its employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal information.

For individuals, Impact Talent Solutions shares the data that is necessary to perform its staffing and outsourcing services with other Impact Talent Solutions entities, customers, suppliers, or with service providers that may be engaged to assist in managing the processes required to provide these services.

Any engagement of a customer, supplier, or service provider will be governed by appropriate contractual requirements limiting the use of your information for any purposes beyond those specifically directed by Impact Talent Solutions and requiring that they ensure sufficient administrative and technical security mechanisms are in place to prevent your information from being improperly used, disclosed, or accessed.

We share only the necessary data to facilitate the employment and managed services requested by you, or in order to provide our staffing or outsourcing services, we share your personal information with: our customers or suppliers for potential placement, employment, outsourcing and related professional services opportunities; our customers or suppliers who are seeking employees that match your qualifications and profile; the company to which you have been assigned to work, in order to integrate with their application and employment processes; managed service providers that administer and manage contingent workforce programs for our customers; service providers that perform outsourced administrative services on our behalf, such as applicant tracking systems, human resource information management, payroll processors, and benefit administrators, and our information technology vendors for data storage or hosting, business continuity, and disaster relief.

At all times, Impact Talent Solutions shares your personal data with these third parties only for recruitment, placement, employment, outsourcing and related professional purposes.

We also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to access your information to provide services to you or for one of the other purposes set out in this Privacy Policy. These include tax authorities, credit reference agencies, anti-fraud databases and agencies, and screening agencies.

As a result of the global scope of Impact Talent Solution’s operations, the sharing of your information with other Impact Talent Solutions entities, service providers, suppliers, and customers may result in your data being sent to countries outside of your country of residence, which may have data protection laws that differ from those in your country of residence. The areas in which recipients are located will vary based on the nature of the services but may include the United States and Canada. Regardless of the source or destination location of your information, Impact Talent Solutions will at all times protect your information as described in this Privacy Policy and abide by all applicable data protection laws. Impact Talent Solutions remains responsible for information that we share with third parties for processing on our behalf.

Your personal data may be transferred to other third-party organizations in certain scenarios: If we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality; If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you; If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police, or

If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

DATA SUBJECT’S RIGHTS

We respect your right to access and control your information and comply with applicable data protection laws and regulations. The amount of personal information you are required to supply when engaging our services is consistent with Impact Talent Solution’s interests in providing our services to you.

We process personal information about you for the purposes set out in this Privacy Policy, including to provide recruitment, placement, employment, outsourcing or related professional services, operate our business, comply with our legal and contract obligations, and fulfill other legitimate interests of Impact Talent Solutions. In most countries in which Impact Talent Solutions has an employment contract with you, the processing of contact, payroll, and benefit information is a contractual or statutory obligation, and failure to provide information to allow processing may restrict your ability to be employed by Impact Talent Solutions.

You may have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.

OTHER PRIVACY RIGHTS

Under the laws of some jurisdictions you may have the right to request additional information about the personal information we collect, request access to the personal information we process, correct an error or omission, delete personal information, or object or limit further processing. Impact Talent Solutions adheres to applicable data protection laws and will respect individual rights requests under those laws.

Because processing your information is necessary to the performance of recruitment, placement, and employment, outsourcing and related professional services that Impact Talent Solutions provides to you, a request to exercise certain rights may result in Impact Talent Solutions being unable to continue providing its services such as recruitment, placement, employment, outsourcing or related professional services. Subject to applicable law, Impact Talent Solutions also may limit or deny requests or charge reasonable fees.

DIRECT MARKETING

We may periodically use your contact information to send you updates via e-mail in order to alert you to opportunities or services relevant to your interactions with us, such as jobs in our database that match your selected criteria.

At the point where we request personal information about you, our site also gives you the opportunity to decide which communications you wish to receive. When your interactions with Impact Talent Solutions have resulted in your registration for multiple services or resources it may be necessary to opt out from each service separately.

You can opt-out of receiving direct marketing from us at any time. Each marketing communication will provide instructions on how to opt out of receiving similar e-mails from the registered service or resource. You can also opt-out by contacting the Data Protection Officer at privacy@impacttalentsolutons.com.

HOW WE PROTECT YOUR INFORMATION

Impact Talent Solutions takes care to secure your personal information.

We regularly monitor industry standards for securing information and review our physical, technical, and organizational security practices in order to determine how best to prevent the loss, misuse, alteration, unauthorized access, destruction, or disclosure of your personal information.

Any personal information sent to us, either in writing or e-mail, may be insecure in transit and we cannot guarantee its delivery. Some of the information you may enter on our web site may be transmitted securely via Secure Sockets Layer SSL, 128 bit encryption services. Pages utilizing this technology will have URLs that start with HTTPS instead of HTTP.

Passwords must be kept confidential and not disclosed to a third party. Impact Talent Solutions will not ask you for your password.

COOKIES

As you visit our web site, the site uses its cookies to differentiate you from other customers. In some cases, we also use cookies to prevent you from seeing unnecessary advertisements or requiring you to log in more than is necessary for security.

Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our web site and which parts of the site are most popular. This helps us gather feedback in order to constantly improve our web site and better serve our customers. Cookies do not allow us to gather any personal information about you and we do not generally store any personal information that you provided to us in your cookies.

YOUR CONSENT

By using our web site or providing personal information to Impact Talent Solutions you consent to our collection and use of your personal information as described in this Privacy Policy.

NOTIFICATION OF CHANGES

This Privacy Policy is subject to periodic review and change. In order to view the current Privacy Policy, simply check this section of the website.

If we materially change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate, so users are aware of what information we collect, how it is used, and under what circumstances, if any, we disclose it. In some cases where we post a notice, we may also email users who have opted to receive communications from us, notifying them of the changes in our privacy practices.