Create Talent Group Inc. Privacy Policy

Effective Date: September 9, 2024

Create Talent Group “CTG” has created this privacy policy to demonstrate its commitment to protecting and maintaining user privacy. The following discloses our information gathering, use and dissemination practices for the Website at www.createtalentgroup.com and any other site administered by Create Talent Group (collectively, the “Website”). Create Talent Group reserves the right to change this policy at any time by posting a new privacy policy at this location.

Protecting the privacy and information of our clients, candidates, and external stakeholders is paramount. With attention, focus, and care, CTG is responsible for the personal information entrusted to us to help humans find their dream jobs and great organizations looking to grow and evolve. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in compliance with applicable privacy laws, including Law 25, BC PIPA, and GDPR, and all jurisdictions in which we operate, as well as our practices when working with third-party vendors. You consent to the practices described in this policy by using our services.

Now, let’s get to the details.

1. Personal Information Collection

Unless otherwise set out below, CTG is the Controller of personal information (“Controller” within the meaning of applicable data protection legislation). For greater clarity, Controller means the entity that decides why and how personal information is Processed. As the Controller, CTG will determine the purposes and means of processing your personal data alone or jointly with agreed-upon client partners.

We collect personal information relevant to providing our recruitment consultancy services. This could include but is not limited to:

Contact details (name, email, phone number, address)
Social Media and online presence, such as URLs to LinkedIn, ArtStation, X (formerly Twitter), Facebook, Behance, Dribble, GitHub, StackOverflow, etc.
Employment history
Education background
Professional qualifications
References
Any other relevant information shared with us during the recruitment process, such as pronouns and city/country of residence

Applicants and Sourced Candidates

We use your personal information when applying and/or interviewing for opportunities with CTG clients and/or when providing support and strategy, which include services in the field of recruitment and selection, temporary staff, secondment, career development, career guidance, executive and job coaching, headcount and strategic planning, and personnel and salary analysis and strategy as further described in the Terms and Conditions (collectively “Services”).

Personal Information We Collect

As a candidate, we collect and process personal information about you, such as:

Identification information – we may process your name, contact information (including home address, home phone number, and mobile phone number), citizenship and country of residence, date of birth, (in exceptional cases) gender, digital signature, and languages spoken.
CV/resumes and other recruitment information – we may process your CV/resume, work history, information about your skills, your experience and educational background, and other relevant information (such as your photograph, interview notes, and personal data included in the cover letter or as part of the application process).
Compensation and benefits information – we may process personal data relating to your current and desired compensation and benefits, including (without limitation) your bonus, recurring payments, and benefits.
Government-issued identifiers – we may process government-issued identifiers, including (without limitation) the social insurance number and social security number, as legally required ONLY during the onboarding phase where CTG is directly involved.
This information may be obtained directly or indirectly from you. In the latter case, we will inform you of the purpose and data sources we use when communicating with you in connection with our Services (e.g. to inform and correspond with you about a company or job opportunity). The exception is where providing this information to you would cause disproportionate efforts. In that case, we may take alternative measures to protect your rights and freedoms.

Why CTG Needs Your Personal Information

CTG processes your personal information only for the purposes specified below:

To provide our Services to you (including matching and proposing you to clients, interviews, and assessments). For example, we may Process your personal information to recommend jobs to you based on your profile and enable our consultants to provide you with tailored job opportunities, career advice, reskilling options, and inclusiveness, suggest additional training where necessary, and introduce you to hiring managers.
Training, Career Development, and updating of systems/statistical purposes. Some systems we use to provide our Services are based on machine learning technology. For that technology to function reliably, it must be trained and updated based on existing data. We may also process personal data in an aggregated manner for statistical purposes.
Resolve and navigate disputes with management and litigation and handle any reports through CTG’s misconduct reporting procedure.
Compliance with labour/employment, tax, and social security laws and other legal or regulatory requirements (e.g. equal opportunity and workplace diversity requirements)

Events
Facilities, security, and contingency planning purposes
To conduct corporate transactions (including mergers, acquisitions and divestments)

2. CTG’s Use of Personal Information

We use your personal information for the following purposes:

To match your qualifications and experience with aligned companies and job opportunities
To contact you regarding potential job openings and throughout the interview process
To communicate with you about your application status
To communicate with you during various stages of HR Consulting practices like coaching, planning meetings, 1:1 meetings, and other professional-related activities
To improve our services and tailor them to your preferences
To comply with legal obligations and regulatory requirements

Correcting / Updating Your Information

If your contact information (i.e., e-mail address, phone number, etc.) changes or needs to be corrected, please e-mail Nathalie Mathieu via nathalie@createtalentgroup.com with your correct, updated information.

Opt-Out / Unsubscribe

If at any time you decide to no longer receive information from Create Talent Group or allow Create Talent Group to share your information with other parties, you may do so by e-mailing Nathalie Mathieu at nathalie@createtalentgroup.com or by contacting us as outlined below.

3. Disclosure of Personal Information

With your consent, we may disclose your personal information to:

Prospective employers who have career opportunities aligned with your qualifications
Third-party service providers who assist us with various functions
Legal authorities and regulatory bodies, as required by law

4. How your Information is Shared

Your information might be shared:

With CTG clients, within the scope of our Services, including recruitment and provision of temporary work, as well as to facilitate a transfer of employment (“temp-to-perm”)
With third parties providing HR-related services to use (e.g. payroll service providers).
With third-party providers of IT-related services (e.g. we may use an external provider to support our IT infrastructure; e.g. an essential part of our software and databases sit in a cloud environment which a third-party service provider operates).
With third-party providers of marketing-related services (e.g. we may store your personal information in a cloud-based CRM application that is hosted and provided by a third-party service provider; e.g. when we use a third-party service provider to organize an event, we may share your data with that third party to invite you to that event).
With providers of professional services (e.g. our auditors, our tax advisors, our legal advisors).
With public authorities (e.g. pursuant to applicable law, CTG must disclose personal data to the social security and tax authorities).
With law enforcement authorities, courts, and regulatory authorities (e.g. as part of a criminal investigation, police services may require us to disclose personal data to them).

We may also disclose your personal information to third parties:

if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets or;
if a third party acquires all or a substantial part of our assets, the personal information we hold about you may be one of the transferred assets.

When we share your personal information as described above, such personal data may be transferred outside Canada, depending on the hiring teams or other deciding factors. If we transfer your personal information internationally, we will only do so in line with applicable law and in line with the context of the expectations and processes already discussed. In this case, we will require that there is an adequate level of protection for your personal data and that appropriate security measures are in place.

For more information about the safeguards we have implemented to protect your personal information internationally, please email Nathalie Mathieu at nathalie@createtalentgroup.com

5. Your Rights:

You have the right to:

Access the personal information we hold about you
Rectify inaccuracies in your personal information
Withdraw consent at any time
Request that all personal information stored by CTG be deleted
Request erasure of your personal information, subject to legal obligations
Object to the processing of your personal information

6. Security

We implement technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, or unintended disclosure. However, no data transmission over the internet and with clients can be guaranteed 100% secure.

7. Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. CTG maintains record retention schedules to ensure that personal information is retained only as long as reasonably necessary to fulfill the purposes for which such data was collected or otherwise meet valid legal or business requirements.

CTG will delete candidate data within one month of the candidate’s request.

CTG will delete employee personal data within seven years of employment termination.

8. Changes to Privacy Policy

We may update this Privacy Policy occasionally to reflect changes in our practices or for legal reasons. The most current version will be posted on our website, and the latest revision date will be indicated.

9. Acknowledgement and Questions?

If you have any questions or concerns about our privacy practices, wish to exercise your rights, or need to contact us for any reason related to your personal information, you can reach us at:

Data protection officer:
Nathalie Mathieu
nathalie@createtalentgroup.com

This Privacy Policy applies to CTG and its current and future subsidiaries. It is important that you read and understand this policy. If you do not agree with our practices or have specific feedback about how we can improve our data protection, please let us know.

You consent to the practices described in this Privacy Policy by using our services.