1. WHO WE ARE
1.1 Talent 2U Direct Ltd (“we”, “us”, or “our”) operates recruitment services and technology platforms designed to connect employers with professional candidates. We are registered in England and Wales under company number 17256191.
1.2 Our services include:
• Talent 2U Direct – a confidential talent marketplace accessed by employers
• Jobs 2U Direct – a candidate registration platform
• integrations with partner recruitment agencies and recruitment technology systems
1.3 Talent 2U Direct Ltd is the data controller responsible for personal data collected through the Talent 2U Direct platform.
1.4 This Privacy Policy explains how we collect, use, process, and protect personal data when employers and other users access the Talent 2U Direct platform.
2. PLATFORM OVERVIEW
2.1 Talent 2U Direct is a confidential recruitment marketplace that enables employers to identify potential candidates through anonymised professional profiles.
2.2 Candidate profiles are sourced from direct registrations via Jobs 2U Direct and from partner recruitment agencies.
2.3 Profiles are initially displayed to employers in anonymised format, excluding identifying information such as name, contact details, and current employer.
2.4 Where an employer wishes to engage with a candidate profile, they may send a job invitation through the platform. If the candidate accepts, identifying details are disclosed to enable further communication.
3. DATA ROLES
3.1 Talent 2U Direct Ltd acts as data controller for all personal data collected and processed through the Talent 2U Direct platform.
3.2 Partner recruitment agencies act as independent data controllers for their own candidate relationships. Where agencies share candidate data with us, they do so under their own lawful basis and remain responsible for that relationship.
3.3 Employers become independent data controllers in respect of any candidate personal data disclosed to them following acceptance of an invitation, and are responsible for their own compliance with applicable data protection law from that point.
4. PERSONAL DATA WE COLLECT
4.1 Employer Data: contact information (name, email, telephone), company details, account credentials, and billing information where applicable.
4.2 Candidate Data: professional experience, qualifications, skills, salary expectations, and career preferences. This data is presented to employers in anonymised form; identifying information is only disclosed with candidate consent.
4.3 Technical Data: IP address, device and browser information, activity logs, profile view records, and usage data.
4.4 Communication Data: correspondence with our support team and platform communications.
5. HOW WE USE PERSONAL DATA
5.1 To operate the platform, display anonymised candidate profiles, facilitate job invitations, and manage employer accounts.
5.2 To disclose candidate identity to employers following acceptance of a job invitation, in accordance with candidate consent.
5.3 For platform security, fraud prevention, and compliance monitoring, including maintaining records of profile views and introductions.
5.4 For analytics and service improvement, to enhance the employer and candidate experience.
5.5 For legal and regulatory compliance, including responding to lawful requests from regulators or law enforcement.
5.6 To share relevant platform and candidate data with Talent 2U Direct LLC, our affiliated company registered in Florida, USA, to support the delivery and operation of our recruitment services and technology platforms. Any such transfer is subject to appropriate safeguards as described in clause 9.
6. AUTOMATED PROCESSING AND PROFILING
6.1 We use automated processing to rank, match, and surface candidate profiles in response to employer searches and criteria. This processing does not produce legal or similarly significant effects for candidates.
6.2 Candidates have the right to request human review of any automated decision that significantly affects them. Employers wishing to raise concerns about automated matching should contact us using the details in clause 14.
7. LAWFUL BASIS FOR PROCESSING
7.1 Contractual necessity – processing required to deliver the recruitment platform service.
7.2 Legitimate interests – operating and improving our platform, fraud prevention, enforcing our Terms of Use including introduction fee obligations, and maintaining platform integrity.
7.3 Consent – in respect of candidate profile promotion and identity disclosure.
7.4 Legal obligations – where processing is required to comply with applicable law.
8. SHARING PERSONAL DATA
8.1 We may share personal data with:
• Employers, upon candidate acceptance of a job invitation (candidate identity only)
• Partner recruitment agencies, in connection with candidate profiles they have supplied
• Technology and service providers who support platform operations, acting as data processors under our instruction
• Professional advisers, regulators, and law enforcement where required by law
• Talent 2U Direct LLC, our affiliated company registered in Florida, USA, for the purpose of supporting and delivering our recruitment services and platform operations
8.2 We do not sell personal data to third parties.
9. INTERNATIONAL TRANSFERS
9.1 Personal data may be transferred outside the UK in the following circumstances: (a) to Talent 2U Direct LLC, our affiliated company in the United States, for the purposes described in clause 5.6, under a UK International Data Transfer Agreement (IDTA) executed between the two entities; and (b) to technology providers or partners who operate internationally, under standard contractual clauses or other UK GDPR-compliant mechanisms. A copy of the applicable safeguards is available on request by contacting us using the details in clause 14.
9.2 The United States does not benefit from a UK adequacy decision covering all commercial data transfers. Transfers to Talent 2U Direct LLC are therefore made under an IDTA, which requires the recipient to provide equivalent protections to those required under UK GDPR.
10. DATA RETENTION
10.1 Candidate profiles: retained for up to 24 months from the date of last activity, or in accordance with the relevant agency’s retention policy where the profile was supplied by an agency.
10.2 Employer account data: retained for the duration of the employer relationship and for up to 6 years thereafter for legal and compliance purposes.
10.3 Technical and activity logs, including profile view records: up to 12 months.
10.4 Legal and compliance records: up to 6 years.
10.5 We will delete or anonymise personal data once it is no longer needed for the purpose for which it was collected.
11. DATA SECURITY
11.1 We maintain appropriate technical and organisational security measures to protect personal data against unauthorised access, loss, or disclosure. These include secure infrastructure, encryption, and access controls.
11.2 In the event of a personal data breach that is likely to result in a risk to rights and freedoms, we will notify the ICO and affected individuals in accordance with our legal obligations.
12. YOUR RIGHTS
12.1 Under UK GDPR, individuals have the following rights in respect of their personal data:
• Right of access – to obtain a copy of your personal data
• Right to rectification – to correct inaccurate or incomplete data
• Right to erasure – to request deletion in certain circumstances
• Right to restriction of processing – to limit how your data is used
• Right to object – to processing based on legitimate interests
• Right to data portability – to receive your data in a structured, machine-readable format
• Right to withdraw consent – at any time where processing is based on consent
12.2 To exercise any of these rights, please contact us using the details in clause 14.
12.3 You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.
13. CHANGES TO THIS POLICY
13.1 We may update this Privacy Policy from time to time. Where changes are material, we will notify affected users by email or by a prominent notice on the platform. Continued use of the platform following notification constitutes acceptance of the revised policy.
14. CONTACT
14.1 Talent 2U Direct Ltd – support@talent2udirect.com
