UK Hays Hub 
Client Platform Privacy Policy

INTRODUCTION

• This Privacy Policy explains what we do with your personal data when you sign up for and use our digital platform website and related services (the "Hays Client Platform"). The Hays Client Platform is designed to provide a range of services to Clients who have registered to find and manage Work Seekers with Hays through the Hays App.
• This Privacy Policy describes how we collect, use and process your personal data in connection with the Hays Client Platform, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• This Privacy Policy applies to the personal data of users of the Hays Client Platform who are Clients. If you use the Hays Client Platform in the course of your employment at one of Hays' clients (for example, if you work in Human Resources and use the Hays Client Platform to help you manage Work Seekers with whom the client has engaged), you will be a "Client" for the purposes of this Privacy Policy.
• For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) and the UK General Data Protection Regulation (either or both, the "GDPR")), the company responsible for your personal data ("Hays" or "us") can be found here.
• It is important to point out that we may amend this Privacy Policy from time to time. Please check this page from time to time as we will post any changes here.
• If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
• When you are invited by Hays to enrol onto the Hays Client Platform as a Client, please note that we will process your personal data in accordance with both this Privacy Policy, which addresses how we process your personal data in the course of providing you with services via the Hays Client Platform, and the Hays General Privacy Policy, which addresses how we process your personal data in the course of providing services and interacting with you outside of the Hays Client Platform as a Client.

HOW TO USE THIS PRIVACY POLICY

• This Privacy Policy gives you an insight into how we use your personal data and what your rights are in relation to this. The Privacy Policy is divided into the following sections:
• How do we collect your personal data?
• What kind of personal data do we collect and how do we use it?
• Our legal bases for processing your data
• Use of and links to third parties
• Who do we share your personal data with?
• How do we safeguard your personal data?
• How long do we keep your personal data for?
• How can you access, amend or take back the personal data that you have given to us?
• How do we store and transfer your data internationally?
• Who is responsible for processing your personal data when you access the Hays website?
• What are cookies and how do we use them?
• This Privacy Policy also contains a number of defined terms, so we have included a glossary at the end of this document. If you are unsure what any of these defined terms means, you can simply click on the term and a hyperlink will take you to the relevant part of the glossary.

THE PRIVACY POLICY

How do we collect your personal data?

• When you use the Hays Client Platform, we collect your personal data in the following ways.
  • Directly from you: If you use the Hays Client Platform as a Client, you will need to complete the sign-up process which will require you to provide us with some limited personal data.
  • From our internal Systems: Where you have previously interacted with Hays, then we may already have your details on our Systems. We may use this information we hold about you to enhance your experience of using the Hays Client Platform by doing things like pre-populating certain information fields when you complete our sign-up process.

 What kind of personal data do we collect and how do we use it?

• We will need to use certain types of personal data about you in the course of providing you with services via the Hays Client Platform. We describe each of the situations in which we use your personal data (and the types of personal data that we use) below.

• Sign-up process
  • If you are signing up to the Hays Client Platform as a Client, you will need to provide some limited personal data to us or we will use information we already hold about you on our internal Systems. This includes your name, your work email address (this could be a personalised work email address or generic work email address), contact number, passcode, an OTP code to facilitate sign-up, and information related to the organisation that you work for (to the extent this is personal data). We consider that it is in our (and your) legitimate interests to process your personal data in this way, namely so that we can onboard you (and you can be onboarded) onto the Hays Client Platform. For more information about our reliance on the legitimate interests legal basis, please see the section headed 'Our legal bases for processing your data' below.

 Provision of Hays Client Platform Services

• If you are using the Hays Client Platform as a Client, we may also collect the following personal data: details of any preferences in relation to Work Seekers; any personal data you may provide to one of our consultants in connection with the Hays Client Platform and your use of the services. We use this personal data to ensure the smooth running of your use of the Hays Client Platform and the associated services and the administrative processes that we need to run to operate the Hays Client Platform (e.g. in relation to invoicing). We consider that it is in our (and your) legitimate interests to process your personal data in this way, namely so that we can provide you with the service for which you have signed up and information about the types of Work Seekers that you have expressed an interest in. For more information about our reliance on the legitimate interests legal basis, please see the section headed 'Our legal bases for processing your data' below.

• Provision of other services
  • As described above, where you have registered for, or use, the Hays Client Platform, we may also use your personal data to deliver other services to you outside of the Hays Client Platform in accordance with the Hays General Privacy Policy or any other privacy terms applicable to that service. For example, where you sign up to the Hays Client Platform, we will also invite you to use our My Learning service (supported by Go1 – see further the Use of and links to third parties section below). We consider that it is in our (and your) legitimate interests to process your personal data in this way, namely so that we can offer you the most seamless end-to-end service that we can across our different business lines. For more information about our reliance on the legitimate interests legal basis, please see the section headed 'Our legal bases for processing your data' below.

• To help us establish, exercise or defend legal claims
  • In more unusual circumstances, we will use your personal data to help us to establish, exercise or defend legal claims. For more information about our reliance on this legal basis, please see the section headed 'Our legal bases for processing your data' below.

• Improving your experience of our services outside of the Hays Client Platform

We may want to use information that we find out about you when you use the Hays Client Platform in order to improve your experience of the services that we provide to you outside of the Hays Client Platform. We consider that it is in our (and your) legitimate interests to process your personal data in this way, namely so that we can improve and develop our wider service offering to you and provide you with the best overall service that we can. For more information about our reliance on the legitimate interests legal basis, please see the section headed 'Our legal bases for processing your data' below.

Our legal bases for processing your data

• Legitimate interests
  • Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data".
  • We don't think that any of the activities that we have described above prejudice individuals in any way – in fact, they help us to offer you a more tailored and efficient service, (for example, by using profiling methods to personalise your experience with us and our communications with you) so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the right to erasure.

• Establishing, exercising or defending legal claims
• Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
• This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Use of and links to third parties

• Certain of the Hays Client Platform services and functionalities listed above are provided or supported by third parties and subject to those third party terms and conditions of use and privacy policies (if any). These include:

Who do we share your personal data with?

• Where appropriate and in accordance with local laws and requirements, we will share personal data set out in the section headed "What kind of personal data do we collect and how do we use it?" with the following categories of people:

• Any of our group companies;
• Appropriate colleagues within Hays (this may include colleagues in overseas offices);
• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• Third party service providers who perform services or functions on our behalf (including external suppliers and consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology Systems);
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• Third party aggregators;
• Third party service providers who provide services to you via the Hays Client Platform;
• Third party training providers;
• Marketing technology platforms and suppliers; or
• If Hays merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

• In most circumstances, we consider it to be in our legitimate interests to share your personal data with these categories of people or, where applicable, we do so in furtherance of establishing, exercising or defending legal claims. Each of these legal bases as further described in the section above headed "Our legal bases for processing your data"

How do we safeguard your personal data?

• We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately. Details of how to contact us can be found here.

How long do we keep your personal data for?

• We will Delete your personal data processed in connection with the Hays Client Platform from our Systems if we have not had any meaningful contact with you for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
• When we refer to "meaningful contact", we mean your active use of the Hays Client Platform or more generally as a Client even if not related to the Hays Client Platform (for example, if you use other services provided outside of the Hays Client Platform). Your receipt, opening or reading of an email or other digital message from us, will not count as meaningful contact – this will only occur in cases where you sign into the Hays Client Platform or use other services through which you interact with us.
• In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).

How can you access, amend or take back the personal data that you have given to us?

One of the GDPR's main objectives is to protect and clarify the rights of EU and UK citizens and individuals in the EU and UK with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise. Please also note that where you make a request, we will action your request in relation to your personal data that we have collected and otherwise processed in connection with the Hays Client Platform and all other personal data that we may hold about you on our internal Systems as someone who has previously registered as a Client with Hays. By way of illustration, if you request for your personal data to be erased, we will erase all personal data that we hold about you, not just personal data that we have collected and otherwise processed in connection with your use of the Hays Client Platform.

• Right to object
• This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests ; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to users of our Hays Client Platform. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
• Right to withdraw consent
• Where we have obtained your consent to process your personal data for certain activities (including soft opt-in for marketing purposes), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR)
• You may ask us to confirm what information we hold about you at any time, andrequest us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.
• Right to erasure
• You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data is no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the UK GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
• We would only be entitled to refuse to comply with your request for one of the following reasons:
  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data we will Delete the relevant data.
• Right to restrict processing
• You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either one of the circumstances listed below is resolved: (i) you consent is obtained; or (ii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important United Kingdom, EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification
  • You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right of data portability
  • If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Hays account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
• Right to lodge a complaint with a supervisory authority
• You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.
• If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
• You may ask to unsubscribe from marketing communications from us at any time. Details of how to do so can be found here.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the period for which we hold your data.

How do we store and transfer your data internationally?

• So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:
• between and within Hays entities; and
• to the third parties referred to in the Who do we share your personal data with section below.
• We store the data that we hold about you in connection with the Hays Client Platform on our internal Systems that we also use to provide you our other services outside of the Hays Client Platform. This also means that certain information held in connection with the Hays Client Platform will also be updated on our wider Systems. We will process this data in accordance with both the terms of this Privacy Policy and the Hays General Privacy Policy.
• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) or the United Kingdom where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

• by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission or approved under the laws of the United Kingdom for the transfer of personal data by data controllers to data controllers and processors in jurisdictions without adequate data protection laws;

• transferring your data to a country where there has been a finding of adequacy by the United Kingdom under UK adequacy regulations in respect of that country's levels of data protection via its legislation;
• where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the UK in order to meet our obligations under that contract if you are a Client of ours); or
• where you have consented to the data transfer.
• To ensure that your personal data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Who is responsible for processing your personal data when you access the Hays website?

• You can find out which Hays entity is responsible for processing your personal data and where it is located by following this link.
• If you have any comments or suggestions concerning this Privacy Policy please follow this link. We take privacy seriously so we'll get back to you as soon as possible.

What are cookies and how do we use them?

• The following section is relevant only where you are using the Hays App to access a web browser (for example, where you click on a link in the app taking you to the Hays website or third party website), and not more generally to your use of the Hays App.
• What's a cookie?
• A "cookie" is a piece of information that is stored on your device's hard drive and which records your navigation of a website or mobile app so that, when you revisit that website or app, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
• Cookies are used by nearly all websites, and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
• If you do not want to receive cookies that are not strictly necessary to perform basic features of our Hays Client Platform, you may choose to opt-out by changing your browser settings.
• Most browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our Hays Client Platform's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
• For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your device.
• How do we use cookies?
• We use cookies to:
  • ensure the Hays Client Platform and its features run properly, such as allowing you to apply for a role via the Hays Client Platform;
  • remember your previous visits or choices you have made to help personalise your return visits and improve your experience using the Hays Client Platform; and
  • help us track your use of the Hays Client Platform. This enables us to understand how you use the Hays Client Platform and track any patterns that emerge individually or from larger groups. This helps us to develop and improve the Hays Client Platform and services in response to what our users want and need.
• Cookies are either:
  • Session cookies: these are only stored on your deviceduring your browsing session and are automatically deleted when you close your web browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your device; or
  • Persistent cookies: a persistent cookie is stored as a file on your device and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
• Cookies can also be categorised as follows:
  • Strictly necessary cookies: These cookies are essential to enable you to use the Hays Client Platform effectively  and therefore cannot be turned off. Without these cookies, the services available to you on our Hays Client Platform cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our Hays Client Platform. For example, they allow us to count visits, identify traffic sources and see which parts of the Hays Client Platform are most popular.
  • Functionality cookies: These cookies allow our Hays Client Platform to remember choices you make and provide enhanced features. For instance, to provide you with single sign on functionality.
  • Personalisation cookies: These cookies help us to advertise details of potential temporary assignment opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the Hays Client Platform, you may see features that are personalised for you based on your previous activity.

• The table at Annex 3 lists the cookies we use in your jurisdiction, why we use them and what types of cookies they are.

• Third party cookies

• The Hays Client Platform may contain links to other independent websites and to third party services which are not provided by us, including training and other resources offered by external providers, and to services offered by external advisors.
• If you access any of these third party websites, the relevant third party may drop cookies onto your device. The cookies used by these third parties are not under our control, and we have not verified as to whether the relevant third party that use them have complied with applicable legislation in respect of their use of such cookies.

This document contains intellectual property rights (including copyright) which are owned by or licenced to Hays. All rights are reserved. No part of this document may be reproduced in any material form without the prior written permission of the rights owner. Any breach of copyright or other intellectual property right may result in civil action being taken.

GLOSSARY

• Client – refers to those who use the Hays Client Platform in the course of their employment at one of Hays' clients.
• Delete – In this day and age it is virtually impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, as we have explained to you in this Privacy Policy, sometimes we will be obliged by law or regulation, or need for risk-management reasons, to retain the ability to access certain elements of personal data. However, our commitment to you is that once your personal data reaches the end of its nominal retention period, or where we receive a valid request from you to erase it, we will put in place specific operational and Systems measures to ensure that your data is "put beyond use". By this we mean that while the data will still technically exist on an archive system, we will ensure that it cannot be readily accessed by any of our operational Systems, processes or staff. Only a very (and we mean exceptionally) small number of senior staff, in very (and, again, we mean exceptionally) limited and carefully prescribed situations, will be able to restore your personal data so that it can be viewed for those legitimate purposes. Once we are clear that all relevant legally mandated retention periods have expired (which, for present purposes, we expect to be the period of seven years), we will go the additional final step of undertaking a "hard delete", whereby not even that very limited number of senior staff would be able to restore your personal data.
• General Data Protection Regulation – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any related national data protection legislation.
• UK General Data Protection Regulation – means the UK version of the EU General Data Protection Legislation (described above). Since the UK left the European Union, the UK now has its own version, and any references to it should be construed accordingly to include any related UK data protection legislation.
• Systems – telephone, computer, internet and Wi-Fi systems, software and portals, accounts and/or networks belonging, controlled or used by Hays that are used to transmit, undertake and/or receive communications or are otherwise used in the course of Hays' business, including candidate portal software and CRM systems.
• Work Seeker– refers to users of the Hays App in connection with finding assignments and/or undertaking an accepted assignment. The Hays App provides Work Seekers with the ability to find and accept assignments, and manage those assignments.
• Terms of use