EU-US Privacy Shield Privacy Statement
On July 16, 2020, the European Court of Justice invalidated Privacy Shield as a Transfer Mechanism for data between EU and US companies. Even though Privacy Shield was invalidated, TalentQuest will continue to honor its commitments with respect to EU personal data transferred pursuant to Privacy Shield before July 16, 2020. TalentQuest intends to utilize alternate transfer mechanisms going forward for data transfers.
EU-US Privacy Shield Privacy Principles
TalentQuest’s practices regarding the collection, storage, transfer, use and other processing of Personal Information comply with the EU-US Privacy Shield principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight. TalentQuest complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. TalentQuest has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
We notify our consumers and customers located in the EEA about the purposes for which we collect and use Personal Information, the types of third parties to which we disclose the information, the choices consumers and customers have for limiting the use and disclosure of their information, and how to contact us about our practices concerning Personal Information.
Purpose of Collection and Use of Personal Information
TalentQuest collects certain Personal Information such as name, email address, postal address and telephone number. We may collect sensitive Personal Information, as defined by the EU-US Privacy Shield framework, such as information about ethnicity, but provision of this information is voluntary. TalentQuest provides individuals affirmative choice before the information is disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice. We use Personal Information (i) to provide you and your employer with Talent and Performance Management related services (e.g., performance appraisals, goal management, 360 feedback, selection assessments, succession planning, learning management, competency modeling, and/or compensation management), (ii) to respond to your requests, (iii) to evaluate the quality of our services, (iv) to communicate with you about our services and related issues, and (v) for internal administrative and analytics purposes and to comply with our legal obligations, policies and procedures. We do not use Personal Information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant consumers or customers of such uses and offering an opportunity to opt out (or, in the case of sensitive personal information, opt-in).
Onward Transfer of Personal Information
We do not share Personal Information with any non-agent third parties; provided, however, we will share your Personal Information with your Employer pursuant to, and in connection with, the services performed on your behalf and as procured by your employer. TalentQuest will obtain assurances from its agents that they will safeguard Personal Information consistently with this policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is set forth in this policy. Where TalentQuest has knowledge that an agent is using or disclosing Personal information in a manner contrary to this Policy, TalentQuest will take reasonable steps to prevent or stop the use or disclosure. If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data. In addition, we may disclose Personal Information (i) if we are required to do so by law or legal process, (ii) when required to do so in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. TalentQuest’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless TalentQuest proves that it is not responsible for the event giving rise to the damage.
Access to Personal Information
TalentQuest provides consumers and customers with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the EU-US Privacy Shield principles. You may access your profile page by clicking the profile link on the TalentQuest Home Page.
TalentQuest maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
TalentQuest takes reasonable steps to ensure that Personal Information that we collect is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on our consumers and customers to update or correct their Personal Information whenever necessary.
Enforcement and Oversight
Mailing Address: TalentQuest
One Midtown Plaza, 1360 Peachtree St. NE, Suite 200
Atlanta, GA 30309
TalentQuest has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY Privacy and EU-US Privacy Shield Policy Confidential Target Audience: Users, Technical Page 10 of 10 SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
TalentQuest is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). To learn more about the EU-US Privacy Shield program, and to view TalentQuest’s certification, please visit https://www.privacyshield.gov/list.
Last Updated: October 22, 2020