Hay UK
General Privacy Policy

In certain circumstances, Hays provides services to individual employees who work for Client organisations, such as training courses to teaching staff who work for Clients in the education sector. Please note that in this context, Hays requires Clients to communicate the relevant parts of this Privacy Policy (namely the sections directed at Clients, Visitors and Website Users) to their employees.
 

What kind of personal information do we collect?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the sorts of information that we will collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly and in certain circumstances, provide services to your employees. We also hold information relating to your online engagement with Candidate profiles and other material published by Hays, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know:

• Key identification and contact information

About yourself or individual contacts at your organisation, including:

• • Names;
  • Job titles;
  • Telephone numbers;
  • Email addresses;
• Automatically collected information
  • Information relating to your online engagement with Candidate profiles;
  • Information relating to your online engagement with other material published by Hays;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with which you access our services;
  • User choices (e.g. marketing preferences);
  • User reports;
  • Log and troubleshooting information;
  • Device information when you install, access or use our services;
  • Website browsing data e.g. pages viewed (limited to Hays websites);
  • Email engagement with Hays;
  • Location information (inferred from jobs, IP address, application history or system stored data);
  • Account access information (e.g. PIN numbers for account verification purposes);
• Information that others provide about you
  • Extra information that our Candidates may tell us about you, or that we find from other third party sources; and
• Additional information that you choose to tell us
  • Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.
 

How do we collect your personal data?

We collect Client personal data in the following ways:

• Personal data that we receive from you;
• Personal data that we collect or receive from other sources; and
• Personal data that we collect automatically.

Personal data that we receive directly from you

• We both share the same goal – to make sure that you have the best staff for and at your organisation. We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
• The types of information that we receive from you in this way include:
  • Key identification and contact information; and
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

• Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
  • From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
  • From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
  • From delegate lists at relevant events; and
  • From other limited sources and third parties, for example, from our Candidates to the extent that they provide us with your details to act as a referee for them or where they give feedback on a particular assignment.
• The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
   

Personal data we collect via our website or through links and emails

• To the extent that you access our website or read or click on an email or text message from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.
• The types of information that we collect about you in this way include the automatically collected information as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
   

How do we use your personal data?

We use Client information for:

• Providing our services;
• Marketing Activities; and
• To help us to establish, exercise or defend legal claims.
   

Providing our services

• Our services broadly consist of: (i) providing you with Candidates; (ii) RPO services; (iii) MSP programmes; and (iv) consultancy and advisory services. We've listed below the various ways in which we use your data in order to facilitate this.
• We also provide services to your employees such as training courses to teaching staff who work for our Clients in the education sector, which will require us to use their personal data in order to grant them access to these services.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.
• Article 6(1)(f) of the GDPR 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 in relation to which we rely on the legitimate interests condition prejudice Clients in any way. 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 section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.
  
   

Marketing Activities

• Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Global Skills Index to a corporate postal or email address.
• If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities. For more information in relation to your jurisdiction, please go to Annex 3.

Profiling, Algorithms and Automated Decision Making

• Profiling is a type of processing activity which enables us better to understand the information that we collect about you, to help us to develop a personalised “profile” for you. This helps us to gain a better idea of how you like to interact with us and our services, the sorts of requests you like to make of us and, of course, the sorts of things you don’t like.  The purpose of our building this personalised profile is to enable us to provide the best possible service to you and maximise the chances that we will be able quickly and efficiently to provide you with access to content that is most likely to be relevant and helpful to you.
• We will use profiling methods in relation to your personal data if we consider this is necessary for our legitimate interests as detailed in the table below. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• As new and better technology becomes more prevalent, some of our profiling activities and our processing activities which use automated systems such as those described above, may amount to Automated Decision Making within the meaning of Article 22 of the GDPR. This means a process of making a decision by automated means with limited, or even no, human intervention in reaching the decision. We will only use automated decision making in relation to your personal data where we consider this is necessary for the completion of pre-contractual steps taken at your request.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Sharing of data

• We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide you with an MSP programme (or assist another organisation to do so); (iii) to provide you with RPO services (or assist another organisation to do so); to (iv) provide you with consultancy and advisory services and/or (v) to provide services to your employees, such as training courses to teaching staff who work for our Clients in the education sector. Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.

• If you would like to see a more detailed list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

To help us to establish, exercise or defend legal claims

• In more unusual circumstances, we will use your personal data in reliance on the legitimate interests legal basis to help us to establish, exercise or defend legal claims.

In certain circumstances Hays will sub-contract the services it provides to Clients to third party suppliers who perform services on Hays' behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Hays requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.

This section of the Privacy Policy also applies to other parties with which we have a business or other type of relationship (ranging from investors to charitable organisations).
 

What kind of personal information do we collect?

We don't collect much data about Suppliers and other third parties with which we conduct a business relationship (e.g. investors) – we simply need to make sure that our relationship runs smoothly. We'll collect the details of contacts within your organisation, such as names, telephone numbers and email addresses. In the case of Suppliers, we'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when a Supplier engages with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements:
 

• Key identification and contact information

About yourself or individual contacts at your organisation, including:

• • Names;
  • Job titles;
  • Telephone numbers;
  • Email addresses;
  • Business account bank details;
  • Identification number;
• Information that others provide about you
  • Extra information that our Candidates or Clients may tell us about you, or that we find from other third party sources; and
• Additional information that you choose to tell us
  • Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.  

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.
 

How do we collect your personal data?

We collect Supplier and other third party personal data in the following ways:

• Personal data that we receive from you; and
• Personal data that we collect or receive from other sources.

Personal data that we receive directly from you

• We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email.
• The types of information that we receive from you in this way include:
  • Key identification and contact information; and
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
 

Personal data we receive from other sources

• Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
  • From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties. 
• The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
   

How do we use your personal data?

• In most cases, we will use your personal data for the purposes below if we deem this to be necessary for our legitimate interests.
• We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR 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 following activities prejudice Suppliers or other third parties in any way. 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 section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.
   

Sharing of data

• Where we have identified you as a Supplier or other third party and unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers in order to get in touch with you about our services.
• We will generally rely on the same legal bases that we have referred to in the section above.
• If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

What kind of personal information do we collect and how do we collect it?

All we need from referees is confirmation of what you already know about our Candidate or prospective member of Staff, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our Candidate or a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

We will collect your date of birth, contact details and potentially some health information if a member of our Staff has put you down as a dependant or any other kind of beneficiary for a benefit connected with their employment or if a member of our Staff exercises certain employment rights. We may also be provided (by inference) with some limited information about your sexual orientation if a member of our Staff identifies you as a spouse or partner when putting you down as a dependant, next of kin or emergency contact:

• Key identification and contact information
  • Name;
  • Age/date of birth;
  • Marital status;
  • Contact details;
  • Use of Staff member' company vehicle;
• Special category information
  • Details of sexual orientation (inferred) and physical or mental health, for example if this is necessary in connection with a beneficiary's entitlement to a benefit connected with their employment or where you disclose this through providing next-of-kin details;
• Information that others provide about you
  • Extra information that your referrer chooses to tell us about you;
  • Extra information that a member of Staff may tell us about you; and
• Additional information that you choose to tell us
  • Any other information that you may provide to us including when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive. To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.

How do we use your personal data?

We will only use the information that our Candidates or Staff give us about you for the following purposes: 

• If our Candidates or Staff members put you down on our form as an emergency contact, we'll contact you in the case of an accident or emergency affecting them;
• If you were put down by a Staff member or Temporary Worker as a next of kin or dependant or any other kind of beneficiary, we will store your personal data to ensure the personnel records of that Staff member or Temporary Worker are correct, and use your personal data where necessary to provide employee benefits and pay remuneration and disclose your data to the relevant benefits provider; or
• If you were put down by a Candidate or prospective Staff member as a referee, we will contact you to get a reference or give your details to a third party to do this on our behalf. Where you are being asked to give a reference based on their professional experience of a Candidate, and where we think that you may be interested in becoming a Client of ours, we may also use your details to reach out to get in touch in that alternative capacity (subject to any local laws and requirements).

We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.

If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Sharing of data

• Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
• If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

What kind of personal information do we collect?

We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website or mobile apps and to help us manage the services we provide. This comprises information such as how you use our website or our mobile apps, the frequency with which you access our website or mobile apps, your browser type, your type of device, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website or the mobile apps, for example by using the chat function, or when you register for one of our newsletters, webinars or participate in any further offer of our website or mobile apps, we will collect any information that you provide to us, for example your name and contact details:

• Key identification and contact information
  • Names;
  • Telephone numbers;
  • Email addresses;
• Automatically collected information
  • Information relating to your online engagement with material published by Hays;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with and location from which you access our services;
  • User choices;
  • User reports;
  • Log and troubleshooting information;
  • Device information when you install, access or use our services;
  • Account access information (e.g. PIN numbers for account verification purposes); and
• Additional information that you choose to tell us
  • Any other information that you may provide to us including when corresponding with us via email or otherwise,

Please note that the above list of categories of personal data we collect is not exhaustive.
 

How do we collect your personal data?

When you visit our website or mobile apps there is certain information that we will automatically collect, whether or not you decide to use our services namely your IP address, the date and the times and frequency with which you access the website or the mobile apps, the way you browse its content and other technical information. We will also collect data from you when you contact us via the website or the mobile apps, for example by using the chat function or when you register for one of our newsletters, webinars or participate in any further offer of our website or mobile apps.

We collect your data automatically via cookies or similar technology such as tracking pixels and HTML5 Local Storage  in line with the cookie settings that you specify via the “Cookie Preferences” link at either the top or bottom of the website, or the settings in your browser. If you are also a Candidate or a Client of Hays, we will use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to our Cookies Policy.

The types of information that we collect about you in this way include:

• Key identification and contact information; and
• Automatically collected information,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

How do we use your personal data?

We use your data to:

• provide you with the service you registered for or the services you participated in, for example sending you a newsletter or taking part in an online survey;
• protect our Systems from attacks and other illegal activities; and
• to help us to improve your experience of using our website or our mobile apps, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you'll be interested in.

We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to our Cookies Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Sharing of data

• Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers in order to get in touch with you about our services.
• We will generally rely on the same legal bases that we have referred to in the section above.

If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

What kind of personal information do we collect?

If you are a former member of Staff and you want to be part of our alumni network and use our alumni portal, we will collect your name, the contact details that you would like us to use and any other information you would like to provide to us for staying in touch with you. We may also retain certain types of data that we held about you relating to your time with us as a member of Staff:

• Key identification and contact information
  • Name;
  • Age/date of birth;
  • Sex/gender;
  • Photograph;
  • Marital status;
  • Nationality/citizenship/place of birth;
  • Contact details;
• Education and employment information
  • Education details;
  • Employment history; and
• Additional information that you choose to tell us
  • Any other information that you may provide to us including when corresponding with us via email or otherwise.

How do we collect your personal data?

If you are a former member of Staff, we will ask you if you wish to remain part of our alumni network and use our alumni portal just before your departure. If you are interested, we will ask you to provide your name and contact details to us and give you the option to opt into receiving marketing communications that we think will be of interest to you as one of our alumni.

How do we use your personal data?

If you are a former member of Staff and you want to be part of our alumni network and use our alumni portal, we will use your data to engage and stay in touch with you in order to maintain our relationship with you, including by:

• sending you newsletters and reports;
• inviting you to events;
• informing you about special vacancies;
• sending you news about Hays;
• inviting you to participate in opinion polls; and
• sending you messages on special occasions such as your birthday.

In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.

Article 6(1)(f) of the GDPR 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.” If you are not happy about this, you have the right to object and you can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Sharing of data

• Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
• If you would like to see a more detailed list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

What kind of personal information do we collect?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the sorts of information that we will collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will only process the data in those jurisdictions to the extent and under the circumstances permitted by law: 

• Key identification and contact information
  • Name;
  • Age/date of birth;
  • A copy of your driving licence and/or passport/identity card;
  • Vehicle registration number;
  • Email address;
• Education and employment information
  • Current job title/specialism/industry sector;
• Special category information
  • Details of your current health status (e.g. possible COVID-19 symptoms);
  • Temperature checks;
  • Vaccination history (including medical conditions relating to or affecting vaccination);
  • Details of travel arrangements where appropriate;
• Automatically collected information
  • IP address;
  • MAC address;
  • Device information when you install, access or use our services;
  • Location information (inferred from jobs, IP address, application history or system stored data);
  • Account access information (e.g. PIN numbers for account verification purposes);
  • CCTV footage;
• Additional information that you choose to tell us in connection with your visit
  • Registration details for facilities and sites; and
  • Purpose of your visit.

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you are visiting our premises as a Candidate, Client, Supplier/other third party or Temporary Worker, please also refer to the relevant Context-Specific section of this Privacy Policy which contains information about how we process your data in each of these scenarios in addition to the processing activities set out in this section. 

How do we collect your personal data?

We collect Visitor personal data in the following ways:

• Personal data that you, the Visitor, give to us; and
• Personal data that we collect automatically.

Personal data you give to us

Hays needs to know certain information about you in order to provide you with access to its premises.

Hays will usually collect this information from you upon your arrival at our premises.

The types of information that receive from you in this way include:

• Key identification and contact information;
• Education and employment information;
• Special category information; and
• Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we collect automatically

To the extent that you connect to our Wi-Fi services, or are captured on our CCTV systems, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us.

The types of information that collect about you in this way includes the Automatically collected information described in the section entitled “What Kind of Personal Information Do We Collect?” above.

How do we use your personal data?

We generally use Visitor data for Visitor Management purposes. 

Visitor Management

• We have listed below various ways in which we will use and process your personal data for this visitor management purposes, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR 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 in relation to which we rely on the legitimate interests condition prejudice Visitors in any way. 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 section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• We may collect and use your health-related special category data for the purposes below if we deem it necessary to do so for vital or public interests. Article 6(1)(d) of the GDPR says that we can process your data where it “is necessary in order to protect the vital interests of the data subject or of another natural person”. GDPR Recital 46 adds that: “Some types of processing may serve both important grounds of public interest and the vital interests of the data subject as for instance when processing is necessary for humanitarian purposes, including for monitoring epidemics and their spread”. Article 9(2)(i) of the GDPR says that we can process your special category data where it “is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health”.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Sharing of data

• Where we have identified you as a Visitor and unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers in order to get in touch with you about our services.

• We will generally rely on the same legal bases that we have referred to in the section above.
• If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.
   

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please go to Annex 3.

Where appropriate and in accordance with local laws and requirements, we generally share your personal data with the following categories of people:

• Any of our group companies;
  
• Appropriate colleagues within Hays (this may include colleagues in overseas offices);
  
• Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
  
• 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);
  
• Service providers (whether third parties or our group companies) who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, administration functions, 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;
  
• Marketing technology platforms and suppliers; and
  
• 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.
  

There are also certain categories of people that we share your personal data with if you are a Person whose data we receive (e.g. a referee) or Staff Alumni.

People whose data we receive:

If you are a referee of one of our Candidates, we may also share your personal data with the following categories of people:

• third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws; and
  
• internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations.
  

Staff Alumni:

• If you are Staff Alumni, we may also share your personal data with a number of additional parties in order to facilitate our continuing relationship, for example, we may share your personal data with other Staff Alumni and associated third parties such as our service providers which operate our alumni portal.

• We are committed to taking all reasonable and appropriate steps to protect the personal information 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 information please let us know immediately. Details of how to contact us can be found here.

• 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).
• We set out below the retention practices that we apply to certain categories of people.

Clients and Suppliers:

• If you are a Client or a Supplier we will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in.
• If you have expressly indicated that you're not interested in our services, then we will Delete your personal data from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.

Website Users:

• If you are a Website User we will retain your IP address and any other information that is required to operate the website or our mobile apps for 365 days.

Other Categories of people:

We will otherwise retain your data for as long as it is necessary to achieve the purpose it was collected or processed for. If this time has come or you have expressly indicated that you’re not interested in one of our website or mobile app services anymore, we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation. 

• One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU 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.
• 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 our Website Users, Clients and Suppliers. 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 (for example, in order to use cookies or pixels in certain jurisdictions), 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, and request 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 of the 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. For more information in relation to your jurisdiction, please go to Annex 3.
• 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 are 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 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.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please go to Annex 3.
• 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: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) 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 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 in Annex 2.
• 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 in Annex 1. 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 job alerts and other marketing communications from us at any time. Details of how to do so can be found in Annex 1.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

• You can find out which Hays entity is responsible for processing your personal data and where it is located in Annex 1.
   
• If you have any comments or suggestions concerning this Privacy Policy please follow this link to Annex 1. We take privacy seriously so we'll get back to you as soon as possible.

• 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;
  • to third parties (such as advisers or other Suppliers to the Hays business);
  • to overseas Clients where applicable;                                                  
  • to Clients within your country, where applicable, who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider; and
  • to other third parties as set out in the section entitled “Who do we share your personal data with” above.
• 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) 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 for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
  • by way of scheme approved by the European Commission (whether as a successor to the Privacy Shield or otherwise) which regulates exchanges of person data between jurisdictions; or
  • 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 EEA 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 information 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 information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

• In the course of using our services, You may wish to access independent websites and third party services (e.g. job platforms) which are not operated by us. Such independent sites and third parties are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any). You will need to make your own independent judgement about whether to use any such independent sites, including whether to use any services offered by the third party.
• Occasionally, third party service providers that we have engaged will process personal data that we given to them as a data controller in their own right, for example, for the purposes of: (i) conducting their own internal reporting, (ii) preventing or responding to threats to the security or integrity of their systems; (iii) establishing, exercising or defending their own legal claims; (iv) complying with legal obligations that apply to them; and (v) using personal data in anonymised or aggregated form to improve their own products and services. They will usually have their own privacy policies which set out more detail in relation to these processing activities.

In the event that more than one of the Hays entities listed above jointly determines the means and purposes of processing personal data of the types of individuals listed above, the Hays entities will process such personal data as joint controllers for the purpose of Article 26(1) of the GDPR.

We adhere to the requirements imposed by the GDPR in relation to the establishment of joint controller relationships between Hays entities.

If you wish to exercise your rights under the GDPR in relation to the processing of your personal data by Hays entities operating on a joint controller basis, please contact us using the channels set out above.

• Candidates - include individuals with whom Hays has not had prior contact, but whom Hays reasonably considers would be interested in, or might benefit from, Hays’ services and being considered for any roles advertised or promoted by Hays including permanent, part-time and temporary positions and freelance roles with Hays' Clients (including those individuals who want to become Temporary Workers). Candidates also include applicants for such roles, as well as people who have supplied a speculative CV to Hays not in relation to a specific job, and/or who have engaged with Hays about Hays’ services and/or any roles advertised or promoted by Hays. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Hays' Clients as part of an MSP offering or otherwise will be treated as Candidates for the purposes of this Privacy Policy.
• Clients - while it speaks for itself, this category covers our customers, clients, and others to whom Hays provides services in the course of its business or whom Hays reasonably considers would be interested in our services. In certain circumstances, Hays provides services to individual employees who work for Client organisations, such as training courses to teaching staff who work for Clients in the education sector. Please note that in this context, Hays requires Clients to communicate the relevant parts of this Privacy Policy (namely the sections directed at Clients) to their employees.
• 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 ten 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 (GDPR) – 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.
• Managed Service Provider (MSP) programmes – Clients' outsourcing of the management of external staff (including freelance workers, independent contractors and temporary employees) to an external recruitment provider. 
• Other people whom Hays may contact – these may include Candidates' and Hays' Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
• Recruitment Process Outsourcing (RPO) services – full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.
• Staff – includes current and former employees and interns engaged directly in the business of Hays (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to Hays (even though they are not classed as employees). For these purposes we also include employees of Hays who are engaged to work on Clients' premises under the terms of RPO or MSP agreements. To be clear, 'Staff' does not include individuals hired by Hays for the purpose of being placed with Clients outside of an RPO/MSP arrangement. These individuals are treated in the same way as Hays' Candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Hays fall within the definition of a 'Supplier' for the purposes of this Privacy Policy.
• Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Hays. In certain circumstances Hays will sub-contract the services it provides to Clients to third party suppliers who perform services on Hays' behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Hays requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.   
• Staff Alumni – refers to former members of Staff who have expressed their wish to remain part of Hays' alumni network and to use Hays' alumni portal.
• 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.
• Temp Relationship – means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
• Temporary Workers – includes someone who becomes employed or engaged by Hays for the purposes of undertaking temporary work for a Client or other Hays group company. If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy. The question of whether and the extent to which the Recruits Privacy Policy and the Staff Privacy Policy apply to you as a Temporary Worker depends on local law requirements. For more information in relation to your jurisdiction, please see Annex 3.
• UK GDPR – the GDPR as it forms part of the Laws of the UK by virtue of Section 3 of the UK European Union (Withdrawal) Act 2018.
• Visitors – means individuals who visit Hays premises but who are not members of Hays' Staff.
• Website Users – any individual who accesses any of the Hays websites or any of the Hays mobile applications (apps).