Enabling GDPR Compliance

We released a new GDPR feature for Talentry. This will make all the activities you can perform in the CRM - such as active sourcing, get candidates' applications and collecting personal data - conform to the GDPR law.

For a better understanding of our new update, we made a video for you: 

The following article gives more detailed information about the new GDPR update:

GDPR Consent request process 

Lifecycle Stages

• Requested
• Accepted
• Declined
• Expired
• Withdrawn

GDPR Lifecycle Inside Talentry

Requested

A consent request was sent out to a Talent. This can be the first consent request or a request renewal if there is already an active consent. If there is no active consent, then the talent will be blocked until accepted. A recruiter can not request consent by email if it is already requested - this prevents spam. 

Accepted

A Talent has accepted the consent request that was sent to him. The Talent will be unblocked, and his data is free to use inside the CRM.

Declined

By law, we also have to give the Talent the possibility to deny a consent request. If a Talent denies the consent request, he stays blocked.

Expired 

Consent always has a specific period attached to it. This is customizable which you can read further down. If the consent is expired, the Talent will be blocked again, and his data is no longer accessible.

Withdrawn 

By law, a Talent can withdraw his consent at any point in time. If this happens, the Talent will be blocked, and his data is no longer accessible.

Customization:

Consent Text

Consent plays an important role in the Talentry system. For each contact, you can see a history of which consent text was accepted at which point in time. Talentry also provides best-practice and templates for consent texts that are designed to meet the requirements of GDPR.

However, if required, GDPR consent text can also be customized.

In order to customize it:

• Go to the "Settings"
• Find the point called "Consent Management"
• Press edit consent
• Update/edit or delete the text talents has to consent to
• You can change the text for all languages that are active for your tenant
• you can set up an expiration date for a consent 6, 12 and 24 months

Consent E-Mail

Talentry provides the possibility to send the consent request to talent directly via email. As this is a critical and personal topic we give the option to customize this email. In order to customize this go to the "Settings" and here you can find a point called "Consent Management". Here you can update / change / delete the text of the email. 

Merge tags

In order to personalize the email, we offer different "merge tags". Those tags will be replaced with the actual content upon sending.

{ {  FirstName  } } - Will put the talents' first name in this place before sending

{ { LastName } } - Will put the talents' last name in this place before sending

{ { ConsentLink | Your text link here } } - Will put the link to the consent landing page in this place before sending

Talent Consent Privacy Policy Page

Customers should define their own privacy policy text or create one based on the Template provided by Talentry.
Talentry CRM privacy policy can be published on a dedicated public page with a unique URL.  

Talents can quickly access the privacy policy page in the bottom part f the emails.

As a Recruiter, this public link should be used during personal or 1on1 communication with talents in case of questions. 

Blocking

All contacts entering the system are initially blocked by default if there is no valid consent. This is done to comply with the legal principle of prohibiting personal data processing unless there is a legal basis for it to be pursued

The following applies to blocked contacts:

• For blocked contacts, only a minimal set of data is visible in the system (name and e-mail address).
• Blocked contacts are ignored by functionalities that involve further processing of the contact's profile data. In particular, blocked contacts do not receive campaign communication.
• Contacts are unblocked as soon as valid consent has been given by them.
• Contacts can be manually unblocked only by administrators - Please make sure to have the GDPR consent stored and documented outside of Talentry.

Obtaining consent

Flow 1: Recruiter adds a contact manually

Recruiters can enter contacts into the Talentry system manually. There are various options to choose from for the recruiter with regard to consent:

• The recruiter assures that consent has already been given in accordance with the current consent text. In this case, the contact is fully available and not blocked.
• Sending a consent e-mail containing a personalized consent link. In this case, the contact is initially blocked after creation. This option is only available if a valid email address is provided upon creation.
• Display the personalized consent link after creation so that it can be sent to the contact by any communication method. In this case, the contact is initially blocked after creation.

Flow 2: Transferring contact from Browser extension („Talentry Sourcer“)

A recruiter can use our browser extension "Talentry Sourcer" to transfer profiles to the Talentry CRM with a single click while sourcing on networks such as LinkedIn, XING or StackOverflow. Typically, this happens after a candidate has indicated interest in further contact during the conversation.

When transferring a contact from the browser extension, the recruiter has the same choices regarding consent as when manually creating a contact in the CRM itself.

Flow 3: Request consent from Talent consent Tab

The Consent tab represents an actual state of the consent. At this tab, Recruiters can also request consent by email or personalized consent link, or unblock a talent with Administrator (Super Recruiter) permissions

Flow 4: Send consent request directly from talent list

It is even much faster to request a consent from the talent list, using Talent related actions menu

Flow 5: Send Bulk consent request to several talents at once 

Recruiters can use the bulk actions menu for obtaining consent from several talents at once. It is especially valuable after importing of several talents. Simply select more than one talent in the list and select send consent e-mail from the menu

Proof of Consent

If you are ever audited, having evidence of consent at the ready will help you comply with GDPR commission. By law, you are required to have this proof of consent stored for Talent from the EU.

Keeping evidence of consent means that you must be able to provide proof of:

• Who consented
• When they consented
• What they were told at the time of consent
• How they consented 
• Whether they have withdrawn consent

We store all this data to avoid any kind of misunderstanding in the future.

• Talent name
• Date accepted 
• Exact text accepted
• Exact Question consented
• Expiration Date
• Status

All this information can easily be found on the Talent Profile Consent Tab

Track consent status in the Talent List

When a Recruiter works with the list of talents while creating a shortlist or maintaining an actual Talent pool it is important to have an overview of the consent status.

There are two dedicated columns exactly for that reason.

• Consent Status - with next valuesNo consent - Consent has never been requested Requested - Consent has been already requested by any of the possible ways Accepted - consent has been acceptedDenied, - Talent intentionally denied the consentWithdrawn - Talent revoke consent after some period of timeExpired - Talent consent has expired
• Consent Expiration date - displays the date when consent is going to expire. This field is empty if the expiration date has not been set or consent is missing  

Withdraw and Decline Consent

By law,  The talent shall have the right to withdraw his or her consent at any time.  Prior to giving consent, Talent shall be informed thereof how to withdraw consent and It shall be as easy to withdraw as to give consent.

If consent is withdrawn company/organisation can no longer process the data,  consent status is set to "withdrawn" and talent is blocked. While being on the landing page the first time, Talent still can deny the consent. This gives a better understanding of the exact intent of the Talent. in this case, Consent status will be set as "Declined"

Talentry following best practices in a compliant way:

• Clear and plain language, explicit separation of a consent question
• There is no charge a fee
• Does not require any other information beyond an email address
• Does not require talent to log in
• Does not ask Talents to visit more than one page to submit their request
• Talent can use the same link and process to withdraw consent
• Still, the same link can be used to re-consent again. For example, if withdrawn has been made by mistake

We recommend informing Talent that he can withdraw consent at any time at this link by entering this text:

You can unsubscribe from these communications at any time on this page, using the same link. For more information about our privacy practices, and how we are committed to protecting and respecting your privacy, please review our Privacy Policy.