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 our business activities, including:
- What personal information we collect and when and why we use it
- How we share information within HRG and with our service providers, regulators and other third parties
- Explaining more about cookies
- Transferring personal information globally
- How we protect and store personal information
- Legal rights available to help manage your privacy
- How you can contact us for more support
The HRG entity responsible for your personal information will be the member of HRG that originally collects information from or about you. This may be further explained in separate privacy notices made available when your personal information are first collected by that HRG entity, for example where you or the business you work for engages with us in relation to our services.
You can find out more about HRG, including geographic locations, at www.hrgworldwide.com or by contacting us using the information in the ‘contact us’ section.
You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.
WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT
When we collect information
- Use one of our websites (including our Investor Relations website);
- Contact us using the using the information in the ‘contact us’ section or fill in any enquiry or other forms on the site.
Personal information we collect and use if you use our websites or online services
We may collect various types of personal information about you, including:
- Information you provide when you use the ‘contact us’ facility or fill in any enquiry or other forms on the site (for example, your name, email address and telephone number);
- If you contact us, we may keep a record of that correspondence.
You must always provide accurate personal information and you agree to update it as necessary in the manner specified below. You also agree that, in the absence of any update, we can assume that the personal information you have provided is correct.
How we use your personal information
We use the personal information you provide to us in order to contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact; and/or enable a member of the Hogg Robinson Group of companies and/or the HRG partner network to contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact.
The legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- our use of your personal information is in our legitimate interest as a commercial organisation (for example, in order to communicate with you where requested in relation to our services, and to make improvements to our websites and our services) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Legal Rights Available To Help Manage Your Privacy section below; and/or
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have, for example to make disclosures required by tax authorities, law enforcement and/or our regulatory bodies.
If you would like to find out more about the legal basis for which we process personal information please contact us using the information in the ‘contact us’ section.
DISCLOSURE OF PERSONAL INFORMATION WITHIN HRG AND TO THIRD PARTIES
We share your information in the manner and for the purposes described below:
- within members of the Hogg Robinson Group of companies and/or the HRG partner network for the purposes set out in the section above, and otherwise as necessary to provide you with our services or to manage our business;
- with third parties who manage our business and deliver services. These include data storage providers used in the operation of the site and/or the provision of any of the services provided through it (these providers do not have direct access to the personal information unless specified otherwise on the site);
- where we are required to do so, with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
- a future purchaser of some or all of our assets or, where applicable, the assets of all or part of the Hogg Robinson Group of companies; and
- in the unlikely event that we believe in good faith that we are required to do so, in order to protect our rights/property or those of our clients and/or their employees.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
HRG operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU, including the United States, that are subject to different standards of data protection. HRG will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end, where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
HOW WE PROTECT AND STORE YOUR INFORMATION
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers, destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected and having in place appropriate network and system security measures.
Storing your personal information
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.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us using the information in the ‘contact us’ section. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right of access to personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see ‘Right to object to the processing of your personal information’ below); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which HRG is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
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 using the site’s ‘contact us’ facility. 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.