We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Talking Talent Limited is a company incorporated in England and Wales with company number 05617899, whose registered office is at Milton Gate, 60 Chiswell Street, London, EC1Y 4AG, United Kingdom (referred to as “Talking Talent”, “we”, “us” and “our” in this notice).
Talking Talent is a provider of coaching programmes and consultancy services (coaching programmes) including providing coachees with access to digital coaching platform (TT Online).
Scope of this notice
This notice describes our processing of personal information relating to our coachees in the course of delivering coaching programmes and providing TT Online. For the purposes of data protection laws in the UK and EU, we are the controller in respect of this processing (meaning that we determine why and how to carry out this processing) except in relation to any processing during onboarding of our coachees (see below).
Onboarding
Onboarding of coachees means the receipt of personal data direct from our client (your employer) or from you (the coachee) that permits us to connect with you directly about your agreed coaching programme at the right stage. Any processing during the onboarding stage is carried out by us as a processor, which means that we process the personal data only on the instructions of our clients (your employer) and do not determine why and how to carry out this processing. This notice does not describe our processing activities as a processor. Our processing as a processor on behalf of our clients is governed by contracts with our clients.
The personal information we collect and use
In the course of delivering coaching programmes and TT Online, we collect the following personal information:
Referral/Registration data: information provided by you or your employer in order to register you on the coaching programme and at each stage, support you through your coaching journey, including:
- Personal contact details, including name, job title, email address, telephone number
- Gender
- Employment information such as job title, employer name, office location, business phone number, business email address
- Other relevant information (including level or grade, department, cost centre, employee ID number, results of tests (psychometric or other))
Technical user data: information automatically collected by our platform when you use TT Online, including the IP address and device type of the device you use to access TT Online and the pages you view and links you click when using TT Online.
User login data: your first & last name and work email address, which has been provided to us by you or your employer to enable you to register on the TT Online to set up your user account, together with the following. (* indicates mandatory fields): personal email, company*, country*, job title, department, leave and return date.
Coaching programme data: information you provide to the coaches or other coachees may provide to the coaches about you as part of your or their coaching programme including during coaching sessions.
Session data: the dates and times of coaching sessions you have booked, attended, postponed, missed or cancelled.
Correspondence data: information contained in any communications between you and your coach including communications via email and other instant messaging systems.
Support data: information contained in any request for support or communications between you and our support team such as your name and email address, date and time of your request or communication and details of your support request.
User feedback data: information contained in any feedback forms you complete, including your name and employer and your views and ratings on the coaching programme.
Coach feedback data: information contained in your coach’s assessment of the success of the coaching programme for you, including your name and employer and your coach’s views on how successful the coaching programme has been for you.
Session recording data: your name, voice and image to the extent captured in any recording we make of any session(s) that you participate in.
Marketing data: your name, address and email address provided by you so that we can keep in touch with you in relation to future/new coaching programmes, products and/or services.
Special categories of personal data
Information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life or sexual orientation or genetic or biometric data is known as ‘special category personal data’.
We may collect the following special category personal data:
- Information regarding your health (including disability) where relevant; this may also include parental leave dates
- Information regarding your mental health and wellbeing where relevant
- Relevant medical history including information regarding pregnancies and children where relevant
- Information about your race or ethnicity
We collect this information so that we can tailor the coaching sessions to your needs and so that we can provide to you good quality tailored coaching sessions. Also, you may choose to provide additional information via correspondence with your coach or verbally in coaching sessions.
Information collected from other sources
We also obtain personal information from other sources as follows:
- From cookies on our website for more information on our cookies please see our cookies policy
- Our IT systems for automated monitoring of our websites and other technical systems such as computer networks and connections, communications systems, and access control systems, email and other instant messaging systems
- From a third party with your consent
What does Talking Talent use your personal information for
Below we describe the purposes we use the personal information for, the types of personal information we use for those purposes and our legal bases for doing so.
| Purpose | Type of personal data used | Legal basis |
| Enabling, monitoring and controlling user access to TT Online. | Technical user data
User login data |
Legitimate interests – enabling users to access and use TT Online and ensuring the security and integrity of TT Online and information stored within TT Online. |
| Ensuring that coaches have the information they need to enable them to provide tailored coaching sessions to coachees. | Registration data
Correspondence data Coaching programme data Session data
|
Legitimate interests – our interests in providing good quality tailored coaching sessions to our clients’ employees to help with their personal development and our clients’ interests in improving the wellbeing and success of their employees.
If special category personal data is revealed in registration, coaching programme or correspondence data, we will ask for your consent to this being used. |
| Enabling coachees to arrange coaching sessions. | Session data | Legitimate interests – our interests in providing coaching sessions to our clients’ employees to help with their personal development and our clients’ interests in improving the wellbeing and success of their employees. |
| Enabling coaches to support and encourage coachees between coaching sessions and over the course of the coaching programme. | Correspondence data | Legitimate interests – our interests in providing good quality tailored coaching sessions to our clients’ employees to help with their personal development, and our clients’ interests in improving the wellbeing and success of their employees.
If special category personal data is revealed in correspondence data, we will ask for your consent to this being used. |
| Helping coachees to use TT Online and resolving any problems with accessing and using TT Online. | Support data | Legitimate interests – our interests in providing a convenient platform for our clients’ employees to access TT Online. |
| Inviting coachees to provide feedback. | User feedback data | Legitimate interests – our interests in improving and developing our products and services. |
| Analysing coachees’ feedback, use of TT Online and coaching sessions to inform improvement and development of the coaching programmes, TT Online and other/new Talking Talent products and services. | Referral/Registration data
Coaching programme data Session data Correspondence data Support data User feedback data Coach feedback data Session recording data (in each case anonymised and aggregated so that individual users cannot be identified) |
Legitimate interests – our interests in improving and developing our products and services. |
| Providing our clients (your employer) with anonymised statistics about their employees’ engagement, progress and attainment as a result of participating in the coaching programme. | Referral/Registration data
Coaching programme data Session data User feedback data Coach feedback data (key themes) Support data Session recording data (in each case anonymised and aggregated so that individual users cannot be identified) |
Legitimate interests – reporting to our clients (your employer) to enable them to assess the success and value of the coaching programme and have oversight of their employees’ engagement, progress and attainment. |
| Sending marketing communications (see more on this in the “Using personal data for marketing purposes” section below) | Marketing data
Business contact data |
Our legitimate interests in promoting our business and services to drive sales and sustain and grow our business. |
| Keeping details of our former coachees so that we can keep in touch them in relation to our future/new coaching programmes, products and/or services. | Alumni Data
Marketing data |
Our legitimate interests to connect to our coachees in relation to their coaching programme, our future/new coaching programmes, products and/or services. |
Other purposes:
Record keeping – We may process your personal information for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security – We may process your personal information for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management – We may process your personal information where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal information where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal information where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
We provide our individual coachees access to various applications managed by us (for example Zoom and Webex ). Such applications will contain their own privacy statements explaining why and how personal data is collected and processed by those applications. We encourage our individual coachees using our applications to refer to the privacy statements available on those applications.
Using personal data for marketing purposes
We send occasional emails containing information about our business and services to the following categories of people:
- staff and representatives of our business customers or target business customers; and
- people who have subscribed to receive our newsletter or other marketing communications
If you receive such communications from us and do not wish to, you can tell us by using the unsubscribe link in any email we send to you or emailing info@talking-talent.com
Who we share your personal information with:
Service providers
We use a number of service providers to provide the coaching programmes and TT Online (TTO). We have set out below the service providers we use, the services they provide and the types of personal data they might process. These service providers only process personal data in accordance with our instructions and only to the extent necessary to provide their services, and their processing is subject to contracts with us to ensure they process personal data in accordance with data protection laws in the UK.
| Service provider | Service provided | Types of personal data used |
| Microsoft 365 | Communication, Document Management and Teams – Operating Platform | Referral/Registration data
Coaching programme data Session data Correspondence data Support data User feedback data (in each case anonymised and aggregated so that individual users cannot be identified) Coach feedback data (key themes) Session recording data (only on large scale webinars and with consent) |
| Salesforce | CRM Platform | Client Data (client contacts, client name, bank details)
Contact Data (client and coachee) Referral/Registration data Coaching programme data Session data Correspondence data |
| Acuity | Coaching Booking Platform | Contact Data (client and coachee)
Session Data Coaching programme data |
| Qualtrics | Survey/Feedback Platform | Contact Data (coachee)
Session data User feedback data (in each case anonymised and aggregated so that individual users cannot be identified) |
| Certinia | Finance System (invoicing) | Contact Data (coachee name included in invoicing detail) |
| Dotdigital | Outreach and content tool | Contact Data (coachee)
Session data |
| Mongo | TTO | Contact Data
User Login Data |
| TTO | Technical User Data (Location data, IP address, device information, browser information) | |
| Hotjar | TTO – User feedback | Contact Data
User Feedback Data |
| Mentimeter | Interactive Survey/Presentation Tool | Technical User Data (IP Address only)
Interaction Data |
| Psychometric and Coach CPD Providers* | Online Assessment tools for coaching | Contact Data |
| Zoom* | Video conferencing tool | |
| Webex* | Video conferencing tool | |
| Qualtrics* | Survey/feedback Tool |
The service providers which are not marked with an asterisk are sub-processors of the personal data which means they will only process any such personal data on our behalf and therefore in accordance with our strict instructions.
The service providers marked with an asterisk (*) are data controllers. Controllers are the main decision-makers – they exercise overall control over the purposes and means of the processing of personal data. Therefore, such service providers will provide you with their own privacy policies explaining why and how personal data is collected and processed by those service providers.
Our client/your employer
Your employer will not have access to any of the information you share with your coach. However, we will derive anonymous qualitative and quantitative data from Session data and User feedback data for the purposes of reporting to your employer in respect of its employees’ engagement, progress and key coaching themes (as a cohort rather than as individuals). The data we use for this purpose is anonymised so that it is no longer possible to identify the individuals to whom it relates (unless in the form of a testimonial or similar and only where you have first approved the sharing and use).
Affiliate Coaches
Your coach will have access to your Coaching programme data, Session data, Correspondence data and User feedback data.
Other parties we may share your personal information with:
- Other third parties who help us to run a business, such as marketing agencies, insurers, lawyers, accountants and business consultants, but only if and to the extent necessary for them to carry out the work we engage them to assist us with, for example in relation to a legal claim made against us or obtaining insurance cover
- Talking Talent group companies (TT US and/or TT Asia) for internal administration purposes
Some of those third-party recipients may be based outside the UK— for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK’.
We will share personal information with law enforcement or other authorities if required by applicable law.
There may be also circumstances in which we need to share personal information with other organisations or individuals, such as in order to protect your vital interests or the vital interests of another natural person.
How long your personal information will be kept
- We will hold coachee data for the duration of the contract with your employer.
- Thereafter we will continue to hold your data only so long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly and to keep records required by law. We have set this timeframe at 6 years after the termination of the contract with your employer.
Transfer of your information out of the UK
To coaches
We may transfer your personal information to coaches who are located outside the UK in order to provide coaching in your country of residence, including the following countries:
- Countries within the European Economic Area (EEA)
- Australia
- China
- Dubai
- Hong Kong
- Japan
- Russia
- Singapore
- South Africa
- Sweden
- Thailand
- The United States of America
To service providers
Where we use the service providers identified in the section above “Who we share your personal information with”, this may also involve transfers of your personal information outside of the UK.
To group companies
We transfer some personal information to our group companies that are based in the USA and Hong Kong.
Transfers
Where such transfers are to countries within the EEA, these are permitted under UK data protection law as the UK government deems EEA countries to provide an adequate level of protection for personal information. Japan (private sector organisations) also has been deemed as adequate.
In relation to any transfers to third parties who are based in countries not deemed to provide an adequate level of protection for personal information, we will ensure that appropriate safeguards are in place to protect your personal information (namely the use of standard data protection clauses adopted or approved by the competent data protection authorities). Please contact us (Dataprotection@talking-talent.com) if you would like to see a copy of these standard clauses.
Your rights
Under the data protection laws in the UK , you have a number of important rights free of charge. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal information
- Access to your personal information and to certain other supplementary information
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal information concerning you in certain situations
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal information concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal information
- Otherwise, restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under thedata protection laws in the UK .
If you would like to exercise any of those rights, please:
- Email, call or write to us
- Let us have enough information to identify you, including your username and password where appropriate
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- Let us know the information to which your request relates
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The data protection laws in the UK also give you right to lodge a complaint with a supervisory authority. To make a complaint to a supervisory authority, you may contact the supervisory authority of your choice using contact details made available by that supervisory authority. Relevant contact details for the UK supervisory authority, the ICO, can be found here: https://ico.org.uk/concerns/
Third parties
We may from time to time provide you with hyperlinks to, and details of, third party websites. In general, we have no control over and are not responsible for, the privacy policies and practices of third parties.
Some third party service providers mentioned in this notice may handle your personal data as a controller in their own right (for example, Zoom, Webex and others mentioned above in the section “Who we share your personal information with”). This will tend to be the case where you are asked to register directly with the service provider in order to access our coaching. Any information you provide to these service providers will be subject to their own privacy policy so please review them to see how they will handle your personal data.
Changes to this privacy notice
This privacy notice was last updated on 1st May 2024. Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail or other suitable method.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to Dataprotection@talking-talent.com or write to the Chief Operating Officer, Talking Talent, Milton Gate, 60 Chiswell Street, London, EC1Y 4AG, United Kingdom or call 01491 821850.
Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office.
Our data protection registration number is ZA017840.