Please read and make yourself familiar with the content of this policy before continuing with your application.
HRG Human Resources Team
Hogg Robinson Ltd and its affiliates (collectively referred to as “HRG”, “we”, “us”, and “our”) takes its data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use and share personal information in the course of the recruitment process or during employment/contractor activities.
- Types of Personal Information We Collect
- How We Use Your Personal Data
- Legal Basis of Processing
- Recipients of the Personal Information
- Storage and Period of Use
- Transfer of Personal Information within HRG and to Third Parties
- Contact Point
If you have any questions regarding the processing of your personal information or if you believe your privacy rights have been violated, please contact firstname.lastname@example.org. If you are aware of an unauthorised disclosure of data, please also refer this to email@example.com for guidance as to the applicable reporting requirements.
2. Types of Personal Information We Collect
a) The types of personal information we collect depends on which stage your application has reached in the recruitment process:
(i) Recruitment Phase:
The type of information we collect at the recruitment phase includes, name, email, work experience, address, qualifications, personal information you provide in a CV, contact number, nationality/right to work details including work permit (if applicable), vetting and verification information if permissible and in accordance with local laws.
We may retain personal information you have provided us at the recruitment stage to consider you for suitable vacancies in the future.
(ii) Employment/contractor Phase
To the extent permissible by local laws we may collect the following personal data:
Staff related data
The type of information we collect at the employment phase is home address, date of birth, marital status, passport details, gender, nationality, emergency contact information, tax information, bank account information, dependent information to administer benefits date of commencement/leaving of employment and the name(s) and date(s) of birth of children and other employee dependants
Data Related to your engagement with HRG
Work contact details (e.g. address, telephone number, e-mail), work location, default hours, default language, time zone and currency for location, your worker ID and various system IDs, your performance review information, your work biography, your reporting line, your employee/contingent worker type, your hire/contract begin and end dates, your cost centre, your job title and job description, your working hours and patterns, whether you are full or part time; your termination/contract end date; the reason for termination; your last day of work; exit interviews, references, status (active/inactive/terminated); position title; the reason for any change in job and date of change; your benefit coverage start date;
Regulatory data: records of your registration with any applicable regulatory authority, your regulated status and any regulatory references;
Remuneration and benefits data
Your remuneration information (including salary/hourly plan/contract pay information as applicable, allowance, bonus and merit plans), bank account details, grade, social security number, tax information, third party benefit recipient information;
Absence records (including dates and categories of leave/time-off), holiday dates and information related to family leave;
HR processes data
Allegations, investigations and proceeding records and outcomes, colleague and manager feedback, appraisals, talent programmes, formal and informal performance management processes, flexible working processes, restructure and redundancy plans, consultation records, selection and redeployment data, health and safety audits, risk assessments, incident reports, data relating to training and development needs or training received;
Closed Circuit television footage, system and building login and access records, keystroke, download and print records, call recordings, data caught by IT security programmes and filters; and
Employee claims, complaints and disclosures data
Termination arrangements and payments, subject matter of employment based litigation and complaints, employee involvement in incident reporting and disclosures.
Certain additional information may be collected where this is necessary and permitted by local applicable laws.
b) Special Category Information
Information within this category includes revealing political beliefs, disability, racial or ethnic origin, trade-union membership, genetic or biometric information used to identify an individual, information concerning a natural person’s health, and sexual orientation.
We may collect such information at a late stage in the recruitment process if permissible under local laws and regulations, in particular for the purposes of monitoring the effectiveness of our Equal Opportunities Policy and our legal obligations under the Equality Act 2010.
We will anonymise your information in accordance with retention policy and retain those anonymised records so that management information and reports can be created – for example, to understand how many males and females applied for roles with HRG in the past 12 months or the ethnic diversity of applicants and/or employees. Once those records are anonymised, they cannot be included in any searches made for suitable candidates for a vacancy or used in the records of an employee.
3. How Does HRG Collect Data?
HRG collects and records your personal data from a variety of source:
Information you provide to managers, local human resources, or enter into our systems, your participation in HR processes, emails you send and verbal communications.
Managers and Human Resources –
Information will be provided by HRG personnel where necessary. For e.g. performance related information.
Third Parties –
These may include references from a previous employer, medical reports from external professionals, tax authorities etc., to the extent permissible by local laws.
Monitoring Devices or other means –
This may include building and location access control and monitoring systems, closed circuit TV, telephone logs, and recordings and email internet access logs, to the extent permissible by local laws. The data may be collected by a third-party provider, providing the monitoring services. This type of data is not accessed regularly and may occur for e.g. there is a need to investigate violations of HRG policies, relating to travel, use of the internet etc. More frequent access to such data may occur incidental to an email surveillance program if and to the extent permitted by applicable laws.
We will request certain mandatory information from you required for the effective and efficient administration and management of our relationship with you. Failure to supply some or all of this information may mean that we can no longer continue your employment or engagement.
We may request details of third parties from you, notably next-of-kin emergency information. You must ensure you have their permission to do so.
4. How We Use Your Personal Data
Your personal information is required by the HRG in order to:
a) assess your speculative application or suitability for a specific job.
b) perform our obligations as employers should you be successful in in attaining a job at HRG.
Such processing includes:
a) Employment administration by Human Resources, payroll, benefits, pension, taxation, general management, insurance, superannuation, stock management, security training and anonymised use.
b) Obtaining employer references when onboarding and providing references to your prospective employers should you leave.
c) References and background/criminal records processed through a third-party reference agency if consistent with local applicable laws and regulatory frameworks.
d) Managerial review processes including but not limited to data concerning position and promotions, bonus, performance management, sick leave management, disciplinary and grievance, work schedule holiday entitlement and travel, other expenses made and reason for termination of employment
e) Litigation, settlement of legal claims/disputes, compliance with lawful requirements, compensation.
Your personal information will not be used in any automated decision-making process or profiling and HRG does not resell your Personal Information.
5. Legal Basis of Processing
HRG ensures it has a lawful basis to process any personal information that you provide in an application for a job (speculative or otherwise) or during employment.
Legitimate interest means the interests of HRG in conducting and managing our business to provide you with the best and most secure experience during your employment application or employment at HRG. For e.g. the information enables HRG to fully assess your suitability for a vacancy you have specifically applied for, or speculatively applied for.
We make sure to consider and balance any potential impact (both positive and negative) and your rights under data protection law. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You have the right to object to processing that is administered on this legal basis. Please see Legal Rights Available to help Manage your Privacy below.
Performance of a Contract
Should you become an employee of HRG, both HRG and you will have to enter into a contract of employment. Both you and HRG will be required to perform certain tasks as a result. For e.g. HRG as your employer, will need to pay your salary, business expenses etc.
Compliance with a Legal Obligation
We may be required to process information in order to perform an employment contract we have with you or to take steps at your request prior to entering such a contract. For e.g. to progress your training, development, promotion and career.
We have identified purposes for processing personal information and the specific lawful basis for each. These are relevant to the extent that they are permissible by local laws and can be found at the table here.
The lawful bases that apply to the processing of Special Category information are as follows:
The processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or HRG in the field of employment law, social security and social protection law, to the extent permissible under applicable laws
The processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws.
The processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as medical emergency) or
The processing is necessary for the establishment, exercise or defence of legal claims
This may include the purposes noted here.
Processing relating to criminal convictions and offences and credit checks
Personal information relating to criminal convictions and offences and credit checks will only be processed where authorised by applicable laws.
More than one lawful basis may apply to the same activity. HRG may process your information on the basis of a legitimate interest of a third party or where appropriate, request your consent in order to process your personal information for a specific purpose.
6. Recipients of the Personal Information
HRG will take all reasonable steps to ensure that your personal information is only received by a limited number of authorised individuals within HRG whose role is essential to the HRG’s compliance with its legal and contractual obligations in your employment relationship with the company. Your personal information may be used by managers and representatives from the world-wide legal and HR functions, authorised employees in the IT department and third parties for purposes noted in paragraph 3.
The HRG departments or authorised individuals/entities are:
a) Talent Acquisition
b) Human Resources
e) IT system administrators
f) Hiring managers and/or relevant Heads of Department.
g) Third party benefits and/or service providers authorised by HRG to supply benefits and/or services for the performance of a contract of employment with you.
h) Specific clients for statutory and regulatory purposes, notably within the financial and government sectors
7. Storage and Period of Use
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
HRG is required to meet all applicable regulatory compliance standards for data protection and to take appropriate organizational and technical measures to protect your personal information from misuse, theft, unauthorized disclosure and loss. Where online portals and/or third recruitment platforms are used, HRG ensures that these requirements meet the same security and data protection standards.
For more information please click here to see ‘How We Protect and Store Your Information’.
9. Transfer of Personal Information Within HRG and to Third Parties
We share your Recruitment Data in the manner and for the purposes described below:
a) members of the Hogg Robinson Group of companies in the UK for the purposes set out in the section above headed ‘How We Use Personal Data’; and/or
b) to WorldApp, Inc. (www.worldapp.com) who, on our behalf, assimilate and store on their servers in the USA personal data that you provide if you complete a recruitment enquiry form on the site and provide that recruitment related data to us for disclosure to members of the Hogg Robinson Group of companies in the UK in order that we/they can use it for the purposes set out in the section above headed ‘How We Use Personal Data’.
Please view HRG’s general policy on ‘Transferring Personal Information Globally’ here
10. Legal Rights Available to Help Manage Your Privacy
- There are a number of legal rights that you can exercise in relation to your personal data held by HRG. You have a right to:
- object to HRG processing your personal information
- rectification of your personal information
- access to your personal information
- restrict processing of your personal information
- obtain a copy of personal information safeguards used for transfers outside your jurisdiction
- lodge a complaint with your local supervisory authority
For full information regarding ‘Legal Rights Available to Help Manage Your Privacy’ please click here.
11. Contact Point
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.