Our
privacy policy
Status: 01.09.2023
Introduction
- This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
- This Privacy Policy applies in respect of the personal data of the following categories of people: Candidates, Temporary Workers, Clients, Suppliers and Third Parties, People Whose Data We Receive, Website Users, Staff Alumni, and Visitors.
- If you are:
- a member of Hays' Staff, you should refer to the Hays' Staff Privacy Policy which is available on the Hays Intranet; or
- seeking employment with Hays internally, you should refer to the Recruits Privacy Policy.
- We are subject to applicable data protection legislation including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the UK GDPR. Please note that when we refer to the GDPR throughout this Privacy Policy, we are referring to both the GDPR and UK GDPR.
- The company responsible for your personal data (“Hays”, “we” or “us“) can be found here.
- It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
- If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these in this document.
- This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).
- The Privacy Policy is broadly divided into two sections:
- Context-specific privacy information that applies to the different categories of person covered by this Privacy Policy, as follows:
- General privacy information that applies to all of the different categories of people covered by this Privacy Policy, including:
- Who do we share your personal data with?
- How do we safeguard your personal data?
- How long do we keep your personal data for?
- How can you access, amend or take back the personal data that you have given to us?
- Who is responsible for processing your personal data when you access the Hays website?
- How do we store and transfer data internationally?
- Cookies Policy
- Use of third party services
- This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. You can find country-specific provisions for your jurisdiction here. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.
- This Privacy Policy also contains a number of defined terms (which we distinguish by starting them with a capital letter), so we have included a Glossary at the end of this document.
- This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).
- The Privacy Policy is broadly divided into two sections:
- Context-specific privacy information that applies to the different categories of person covered by this Privacy Policy, as follows:
- General privacy information that applies to all of the different categories of people covered by this Privacy Policy, including:
- Who do we share your personal data with?
- How do we safeguard your personal data?
- How long do we keep your personal data for?
- How can you access, amend or take back the personal data that you have given to us?
- Who is responsible for processing your personal data when you access the Hays website?
- How do we store and transfer data internationally?
- Cookies Policy
- Use of third party services
- This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. You can find country-specific provisions for your jurisdiction here. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.
- This Privacy Policy also contains a number of defined terms (which we distinguish by starting them with a capital letter), so we have included a Glossary at the end of this document.
Context-specific privacy information
This section of the Privacy Policy applies to Candidates.
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.
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 to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.
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;
- Birth number;
- Sex/gender;
- Photograph;
- Marital status;
- Nationality/citizenship/place of birth;
- Contact details;
- Emergency contacts/next of kin information and details of any dependants;
- A copy of your driving licence and/or passport/identity card;
- Education and employment information
- Education details;
- Employment history;
- Current job title/specialism/industry sector;
- Skills and languages spoken;
- Referee details;
- Immigration status (whether you need a work permit);
- Start date or availability date;
- Details about your previous and current remuneration, pensions and benefits arrangements;
- Details of hours worked (once you have been placed in a role);
- Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;
- Financial information
- Bank details;
- Financial information (where we need to carry out financial background checks);
- Social security number (or equivalent in your country) and any other tax-related information;
- Special category information
- Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information, in ease case for diversity monitoring purposes;
- Sexual orientation (for example where you disclose this through providing next-of-kin details);
- Physical or mental health, including disability-related information in order to enable us to make reasonable adjustments and health-related information when we need to use or offer occupational health to you in the context of certain types of roles;
- Details of health-related information arising from or in connection with the COVID-19 or other pandemics, if this is required for a role that you are interested in applying for or where volunteered by you, e.g. a test result (whether positive or negative) or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate;
- In certain circumstances, video recordings of Candidates attending or participating in training or meetings where individuals have consented to the recording;
- Religious Beliefs in order to calculate entitlement to annual leave;
- Criminal conviction data
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Automatically collected information
- IP address;
- Usage information 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 e.g. Hays or Clients’ websites;
- Email engagement history 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 your referees choose to tell us about you;
- Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto, or is otherwise made available to us);
- Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us; and
- Additional information that you choose to tell us
- Any other information that you may provide to us including, for instance, details of your childcare or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information) and 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 collect your personal data?
We collect Candidate personal data in the following ways:
- Personal data that you, the Candidate, give to us;
- Personal data that we receive from other sources; 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 its services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
- There are numerous ways you can share your information with us. These may include:
- Entering your details on the Hays website or via an application form, as part of the registration process;
- Leaving a hard copy CV at a Hays recruitment event, job fair or office;
- Emailing your CV or other information to a Hays consultant or being interviewed by them;
- Applying for jobs through a job aggregator, which then redirects you to the Hays website;
- Entering your personal details into a Hays microsite; or
- Entering a competition through a social media channel such as Facebook or Twitter (or similar).
- The types of information that receive from you in this way include:
- Key identification and contact information;
- Education and employment information;
- Financial information;
- Special category information;
- Criminal conviction data, 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
- We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
- When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);
- Your referees may disclose personal information about you;
- Our Clients, Suppliers, other Candidates and our colleagues within Hays (e.g. in the context of them making a referral) may share personal information about you with us;
- If we receive your personal information from Facebook or Twitter, if you ‘like’ our Facebook page or ‘follow’ us on Twitter (or perform a similar interaction with us on any social media platform on which we have a presence); and
- If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.
- The types of information that we receive about you in this way include the information that others provide about you described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we collect automatically
- To the extent that you access our website or read or click on an email from us, 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. 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 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 Candidate data in five ways:
- Pre-recruitment Activities;
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
- In appropriate circumstances, we also use Candidate data for Profiling.
Pre-recruitment Activities
- When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services (usually via email), subject to any applicable laws and requirements.
- In order for us to do this, we may:
- Collect your personal data;
- Store your details (and update them when necessary) on our database so that we can contact you about our services;
- Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
- Review your information to work out whether and how our services might help you; and
- Contact you about our services.
- We've set out in more detail below various ways in which we will use and process your personal data for the purposes of determining whether our services would be beneficial to you, 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 Candidates 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to work out whether you might be interested in or benefit from recruitment services, including by: - collecting data from Candidates and other sources, such as LinkedIn - storing Candidates’ details on databases - assessing data against vacancies |
- Key identification and contact information - Education and employment information - Additional information that you choose to tell us - Information that others provide about you - Automatically collected information |
Legitimate interests, namely it is in our interests and your interests for us to assess whether you may be interested in or benefit from our recruitment services |
Collecting and processing your data in the course of reviewing your information to ascertain how Hays' recruitment services may assist |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests for us to identify how we can help you with your job search |
Collecting and processing your data in the course of communicating with you in relation to Hays' recruitment services |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to contact and correspond with you as part of providing you with our recruitment services |
Recruitment activities
- Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we will use and process your personal data for this purpose, 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 Candidates in any way – in fact, they help us to offer you a more tailored, efficient service. 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 in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
- When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to provide recruitment services to Candidates and facilitating the recruitment process including by: - Collecting data from Candidates and other sources, such as LinkedIn - Storing Candidates' details on database - Assessing data against vacancies - Sending Candidates' information to Clients, in order to apply for jobs or to assess eligibility for jobs - Enabling Candidates to submit CVs, apply online for jobs or to subscribe to alerts about jobs - Recording Candidates' question and answer sessions and/or video interviews to support our recruitment services (with the recordings being analysed for training/monitoring purposes and/or shared with Clients and viewed via a secure third party platform) - Making video recordings of Candidates' participation in training sessions or meetings for internal training/monitoring purposes and/or monitoring internal compliance standards |
- Key identification and contact information - Education and employment information - Additional information that you choose to tell us (e.g. information that you tell us in a recording) - Information that others provide about you - Video recording footage |
We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with our recruitment services and for you to receive them in order for us to function as a profit-making business, and to help you and other Candidates to find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request To the extent that we record a video of you, we will ask for your consent before we start recording but will rely on legitimate interests in relation to our use of the data for training/monitoring and for monitoring compliance standards |
Processing Candidates' data to facilitate payroll and invoicing processes |
- Key identification and contact information - Education and employment information - Financial information |
Legitimate interests, namely it is in our interests and your interests to: - ensure that our business runs smoothly, so that we can carry on providing services to Candidates like you - ensure that you are appropriately remunerated If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis |
Collecting and processing Candidates' data in the course of carrying out: - customer satisfaction surveys - Hays market research which we will use to inform our marketing materials and other informational materials such as whitepapers, reports and articles (e.g. our salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to: - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary - gain an insight into the careers, goals and aspirations of the Candidates to whom we provide services in order to market our service offering to help differentiate us in a competitive marketplace |
Collecting and processing Candidates' data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support |
- Key identification and contact information - Additional information that you choose to tell us |
We will rely on legitimate interests, namely it is in our interests and your interests to: - address any issues that you have been experiencing - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis in relation to using your data in the course conducting communications relating to our services with you |
Processing Candidates' data to enable them to receive services ancillary to recruitment services, such as participation in: - specialist online training - interactive features of services - recruitment-related services via the Hays App |
- Key identification and contact information - Additional information that you choose to tell us - Information that others provide about you - Certain automatically collected information e.g. User choices and information about your use of these services |
We will rely on legitimate interests, namely it is in our interests and your interests to: - recommend and grant you with access to our specialist online training or some of our more interactive services as this might help with your job search - provide you with the best possible end-to-end service and enhance our service offering to you and to help differentiate us in a competitive marketplace If you have signed up to receive these ancillary services (either separately or because they form part of the recruitment services to which you have already signed up) or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request |
Processing Candidates' data in the course of carrying out Hays' obligations arising from any contracts entered into between Hays and third parties in relation to Candidates' recruitment, such as potential employers to whom we are committed to identifying the most suitable Candidates for roles in their organisations |
- Key identification and contact information - Education and employment information - Financial information - Information that others provide about you - Additional information that you choose to tell us |
We will rely on legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential employers so that we can help you find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is also necessary for the purposes of our contract with you (as well of the third party) |
Verifying details that a Candidate has provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws) |
- Key identification and contact information - Education and employment information - Criminal conviction data - Information that others provide about you - Additional information that you choose to tell us |
For criminal conviction data, we will obtain your explicit consent. For all other types of data: - we will rely on the legitimate interests legal basis, namely it is in our interests and your interests to verify that all of the information that you have provided to us is true and accurate and to obtain references about your prior conduct as part of the process of finding you employment - if you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that verifying details that you have provided or the requests that we need to make are necessary for the purposes of our contract with you. |
In certain jurisdictions, using a web-based video identity verification process to verify a Candidate's identity if we do not meet them in person and document this process |
- Key identification and contact information (including a copy of driving licence and/or passport/identity card) - Additional information that you choose to tell us - Video recording footage |
To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on the legitimate interests condition (it is in our legitimate interests to maintain internal compliance standards) in relation to our use of the data that we capture to verify your identity. For more information in relation to your jurisdiction, please click here |
Collecting and processing Candidate data in the course of carrying out assessment and development activities such as psychometric evaluations or skills tests - for more information in relation to your jurisdiction, please click here |
- Key identification and contact information - Additional information that you provide or choose to tell us during the evaluation/skills test (including in relation to your performance) |
Legitimate interests, namely it is in our interests and your interests for us to provide you with the services of our Assessment and Development departments, namely in relation to psychological assessment and research, assessment centres, competency management, reorganisation issues, management development, career development, mobility, outplacement, career transition and coaching. |
Marketing activities
- We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we will use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
- We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please click here.
- Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by informing one of our consultants that you are interested in our services, submitting a job application or CV, or registering a vacancy to be filled), and we are e-marketing or sending by text message other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. We will use your personal data to send you e-marketing materials with your ‘soft opt-in’ consent if we deem that it is in our legitimate interests to do so.
- For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time 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. Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Using Candidates' data to carry out marketing activities to promote our services through digital channels including in relation to: - marketing our full range of recruitment services (permanent, temporary, contract, outplacement, MSP programmes and RPO services) to you - sending Candidates details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to them - providing Candidates with information about certain discounts and offers that they are eligible for by virtue of their relationship with Hays |
- Key identification and contact information - Automatically collected information |
If we have obtained your contact details from an occasion when you previously engaged with us and we are e-marketing other recruitment-related services of our own, we will rely on soft opt-in consent if we consider that the legitimate interests legal basis applies, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in In all other circumstances, we will obtain your opt-in consent |
Collection of data via cookies or tracking pixels and use of data to show users Hays adverts and other content on other websites, for example, Facebook |
- Key identification and contact information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy) Even where you have turned off advertising cookies, it is still possible that you may see a Hays advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience Please note that if you access Hays' services across multiple devices, you may need to adjust your settings (e.g. if you want to turn off advertising cookies) via the Cookie Preferences link on each of your devices |
Lookalike targeting and other data driven marketing: providing lists of certain Candidates' data to Facebook and Google to enable them to find an audience of people with similar characteristics or demographics to these Candidates (which will not include these Candidates) for Hays' marketing purposes. Facebook's policy is to irreversibly hash such lists prior to use, match the hashed data against their own customers, generate the lookalike audience, then delete the original list and use it for no other purpose. We will not have access to the identity of anyone in the lookalike audience, unless they choose to click on the advertisements. |
- Key identification and contact information - Automatically collected information (advertising identifiers) |
We will obtain your opt-in consent for the collection of advertising identifiers via the Cookie Preferences link on our website We will share these advertising identifiers with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent in which case we will obtain such consent via our consent management tool |
Displaying excerpts from Candidates' profiles for promotional purposes on Hays' website(s) to provide examples of success stories |
- Key identification and contact information - Education and employment information - Additional information that choose to tell us (we may ask you for additional details for the purposes of the story that we tell about you) |
We will always ask for your explicit consent before featuring you in this way on the website |
Use of Candidates' data in the course of making service and marketing communications via WhatsApp |
- Key identification and contact information - Automatically collected information |
We will ensure that you have opted-in (and therefore provided your consent) through one of a number of channels: - when you signing up to WhatsApp job alerts on the website - submitting an opt-in message direct to one of our WhatsApp channels - clicking through on a sign-up button on an invite email. |
Special category data
- We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities and so we will process certain sensitive/special category data about you to facilitate this. Where appropriate and in accordance with local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.
- We will collect other sensitive/special category personal data about you such as health-related information or religious affiliation if this is appropriate in accordance with local laws: Article 9(2)(b) of the GDPR allows us to do this where the processing is “necessary for the purposes of carrying out the obligations and exercising our or your specific rights… in the field of employment and social security and social protection law”, as long as this is allowed by law.
- We may also collect details of any criminal convictions if appropriate in accordance with local laws which may require your consent. If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so by referring to the section entitled “How you can access, amend or take back the personal data you have given us” in the General Privacy Information section of this Privacy Policy.
- Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive/special category data. For more information in relation to your jurisdiction, please click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and analysing Candidates' data in order to assess and ensure our compliance with equal opportunities obligations | Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) keeping under review the existence or absence of equality of opportunity or treatment between groups of people and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Sharing Candidates' data (that has been collected to assess and ensure our compliance with equal opportunities obligations) with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes | Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information | We will obtain your explicit consent before we share your data in this way |
Processing medical history/health-related data to make reasonable adjustments during the recruitment process | Medical history/physical or mental health-related data |
We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. to assess the working capacity of an employee or potential employee for an employer) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing health-related data to when we need to use or offer occupational health to Candidates in the context of certain types of roles (e.g. teaching, nursing or night work) | Medical history/physical or mental health-related data |
We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. the provision of health care or treatment) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing health-related information arising from or in connection with the COVID-19 or other pandemics where this is required for a role that you are interested in applying for or where volunteered by you | Test results (whether positive or negative), or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate |
We rely on legitimate interests, namely it is in our and your interests for us to collect and share your health-related information if this is required for a role that you are interested in applying for We may also rely on the vital interests and the public interest lawful bases, namely to protect against serious cross-border threats to health If local law requires us to obtain your consent, we will do so |
Processing criminal convictions data when carrying out background checks |
Details of any criminal convictions disclosed by Candidate on the Candidate Application Form Details of any criminal convictions obtained via background checks that we are required to carry out where this is necessary for us to comply with our legal obligations in connection with a Candidate's search for work (e.g. if we put a Candidate forward for certain roles which require a certain type of background check to be carried out) |
We will obtain your explicit consent in the Candidate Application Form though where local laws allow us to do so, we may need to request a Disclosure and Barring Service Check (or equivalent applicable check in your jurisdiction) without your consent where this is necessary for us to comply with our legal obligations in connection with your search for work |
Processing certain types of Candidate data in order to calculate entitlement to annual leave |
- Medical history/health-related data - Religious affiliation |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing the sensitive/special category personal data of individuals connected with Candidates, for example: - where a Candidate discloses this to us in the course of providing next-of-kin details - to allow the relevant Candidate to access certain benefits |
Details of sexual orientation, and physical or mental health, including disability-related information |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
To help us to establish, exercise or defend legal claims
- Sometimes it will be necessary for us to process personal data in reliance on the legitimate interests legal basis and, where appropriate and in accordance with local laws and requirements, special category data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
- This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Preserving, sharing and otherwise processing Candidate data to establish, exercise or defend legal claims |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Education and employment information Special category information Criminal conviction data Financial information Automatically collected information Information that others provide about you Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes In the unlikely event that we need to process any special category information or criminal conviction data for this purpose, we will only do so where local law allows us to process such data to establish, exercise or defend legal claims |
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.
- We also sometimes use automated systems such as filtering tools, or occasionally more complex tools which use an element of artificial intelligence, such as algorithms or machine learning (including those provided by third parties), to help us quickly, efficiently and more accurately to analyse data we have about you and other Candidates, as well as data we hold on our Clients' needs, and this ultimately helps us to make decisions based on this data. This can include applying tools which use algorithms (such as filtering tools or machine learning) to Candidate personal data in order to help us come up with the best possible shortlist for a particular role. Such technology should reduce significantly the amount of time needed to consider when Candidates might be the best fit for relevant jobs. This should in turn make the recruitment process much more efficient and effective, which, we hope, will improve your overall experience with us.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that we can show Candidates both targeted and personalised content. This will include: - personalising Candidates' website experience, including in relation to the roles that are brought to their attention when visiting the website - making recommendations for editorial content that we think may be of interest to Candidates (e.g. reports about developments in their industry) - personalising the marketing content that Candidates receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Candidates engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed |
- Key identification and contact information - Education and employment information - Automatically collected information - Additional information that you choose to tell us More specifically, this will include: - Personal information and information about the Candidate's job search (i.e. as submitted via form or pulled through from our Systems) - Details of Candidates' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) - Location data - either inferred from jobs, IP, or application history, or system stored data - Digital identifiers - IP address, personalisation cookies - Website browsing data, form submission data and email engagement data - Marketing preferences |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices. Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: - increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the Hays websites and email campaigns - increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you - encourage you to come back to our website by making this most helpful experience possible - reduce website bounce rate - increase email engagement rate (i.e. the frequency with which users click through) |
We may capture and analyse Candidates' web-based behaviours using various items of data e.g. number of job ads read/applied for online, number and type of articles read, number of web visits made, membership of “talent pools”/segments – see below) in order to award a Candidate a weighted “approachability score” with a view to providing insights into Candidates' needs and to allow Hays to follow up where needed Consultants will use these scores as part of the shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Candidate, which will serve to supplement other data that Hays holds about the Candidate Our collection of web-based data will rely on the personalisation cookies/pixels that we place on your device as part of the personalisation activities as described above |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device However, please note that we may still carry out engagement scoring activities even if a personalisation cookie is not placed on your device (e.g. we may consider the information that we already hold about you on our Systems with a view to allocating you an engagement score even if you have opted out of the personalisation cookie) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to allocating you an engagement score and our subsequent use of this score We consider that it is in our legitimate interests to allocate you with an engagement score in order to help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you
|
We may use the data that we collect via personalisation cookies/pixels e.g. web-based behaviours such as details of Candidates' interactions with the website (e.g. applications, web page visits), to enrich the Candidate data and existing profiles about them that we already hold on our Systems |
- Key identification and contact information - Education and employment information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to using data that we collect about you to enrich your existing profile on our Systems We consider that it is in our legitimate interests to enrich the data that we hold about you to help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you |
Analysing Candidates' data by continuously tracking and monitoring their experience and account activity in order to profile them and allocate them to “talent pools” based on their attributes and behaviours (e.g. previous roles, skills, industry experience, location, when a Candidate is willing to work) Talent pools are used as a means of managing the Candidate database, placing Candidates in roles and marketing to Candidates The assignment of Candidates to talent pools is a fully automated process and can involve the use of bots |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to use profiling methods to place you and your Candidate profile into groups or segments with other Candidates, based on your interests, habits, attributes and/or preferences in order to: - help us to optimise the matching of Candidate profiles to roles and improve the effectiveness and efficiency of the recruitment cycle - allow us to keep track of whether we have enough suitable Candidates to fulfil our business needs and those of our Clients at all times - help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you |
We may use profiling methods in relation to Candidates' data so that we can: - place them and other suitable Candidates on shortlists for particular roles based on prescribed criteria, which will allow our consultants to identify the most appropriate Candidates for roles in the most efficient manner efficiently; and - recommend roles based on how a Candidate's interests, habits, attributes and/or preferences, rank in comparison to other Candidates Our intention is for any such activities (which might involve using automated processes to profile, select, screen, rank, grade, shortlist and/or put forward Candidates for roles) to complement rather than completely replace the activity of our consultants |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to use profiling methods to place you and your Candidate profile into groups or segments with other Candidates, based on your interests, habits, attributes and/or preferences in order to: - help us to optimise the matching of Candidate profiles to roles and improve the effectiveness and efficiency of the recruitment cycle - help our consultants to make decisions in relation to suggesting relevant roles to you If these shortlisting and ranking activities amount to Automated Decision Making for the purposes of Article 22 of the GDPR, we will only conduct these activities where we deem this to be necessary for the completion of pre-contractual steps taken at your request. We think it is reasonable to assume that, as a Candidate, you are hoping to enter into an employment contract, and that by using our services you are asking us to take the necessary steps for this purpose. Such steps might include, for example, checking you meet certain requirements for a particular role. If the role is very popular, we may have to check the eligibility of a large number of potential Candidates – we may therefore use automated decision making to filter this pool of Candidates down to a more manageable number. |
Compliance with a legal obligation
- In some circumstances, we will use your personal data to comply with our legal obligations. Article 6(1)(c) of the GDPR says that we can process your data where it “is necessary for compliance with a legal obligation to which (we) are subject”.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Accessing, preserving and disclosing Candidates' data if there is a valid legal request from a regulator, law enforcement, authority or if we otherwise have a legal duty to do so |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Automatically collected information - Education and employment information - Information that others provide about you |
Compliance with a legal obligation including where: - we are in receipt of a court order to disclose information for the purposes of court proceedings in the context of civil and commercial matters - we are compelled by law enforcement agencies to provide data in relation to a criminal investigation - we need to comply with our obligations under consumer law, for example competition legislation - we need to comply with our obligations under companies legislation and tax law, for example, to provide details of your remuneration and tax paid - we need to comply with our obligations under data protection laws - we need to comply with our obligations under employment laws (e.g. those which require us to track the number of hours you have worked) |
Preserving and sharing Candidates' data with others including law enforcement agencies and to respond to legal requests when we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Automatically collected information - Information that others provide about you |
Even where we are not under a legal obligation to process your data, we will, under certain circumstances, have a legitimate interest in cooperating with law enforcement agencies and other bodies in order to assist, for example, with the prevention and detection of crime |
Processing Candidates' data when verifying documents and information requested from and provided by Candidates to prove that they have the right to work in a particular jurisdiction |
- Key identification and contact information (e.g. a copy of your passport and proof of address) - Education and employment information (e.g. immigration status and work permit if applicable) - Financial information (e.g. social security number or equivalent in your country) |
We will process your data where this is necessary for us to comply with our legal obligations in relation to ensuring that you have the right to work in a particular jurisdiction |
Sharing of data
- We will share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we will also share your information with any of our group companies and associated third parties such as our service providers and selected job aggregators where we feel this will help us to provide you with the best possible service and maximise your chances of getting what you want.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Disclosing Candidates' data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area for the purposes listed in the preceding tables |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Education and employment information - Special category data - Criminal conviction data - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
- The disclosure is necessary (e.g. to potential employers) to conclude and perform any contracts that we have entered into with you (see section entitled Recruitment Activities above) - The disclosure (e.g. to tax, audit, or other authorities) is necessary for the compliance with a legal obligation to which we are subject (see section entitled Compliance with a legal obligation above) - The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims - We have obtained your consent (e.g. when we share your special category data with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes - The disclosure is necessary for health and social care purposes (e.g. to an occupational health specialist to enable the provision of support during the recruitment process if an Candidate suffers from a health condition or disability) - The disclosure is necessary for carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law (e.g. on an intragroup basis when assessing and effecting your entitlement to annual leave/certain benefits) - The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above) |
This section of the Privacy Policy applies to Candidates.
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.
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 to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.
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;
- Birth number;
- Sex/gender;
- Photograph;
- Marital status;
- Nationality/citizenship/place of birth;
- Contact details;
- Emergency contacts/next of kin information and details of any dependants;
- A copy of your driving licence and/or passport/identity card;
- Education and employment information
- Education details;
- Employment history;
- Current job title/specialism/industry sector;
- Skills and languages spoken;
- Referee details;
- Immigration status (whether you need a work permit);
- Start date or availability date;
- Details about your previous and current remuneration, pensions and benefits arrangements;
- Details of hours worked (once you have been placed in a role);
- Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;
- Financial information
- Bank details;
- Financial information (where we need to carry out financial background checks);
- Social security number (or equivalent in your country) and any other tax-related information;
- Special category information
- Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information, in ease case for diversity monitoring purposes;
- Sexual orientation (for example where you disclose this through providing next-of-kin details);
- Physical or mental health, including disability-related information in order to enable us to make reasonable adjustments and health-related information when we need to use or offer occupational health to you in the context of certain types of roles;
- Details of health-related information arising from or in connection with the COVID-19 or other pandemics, if this is required for a role that you are interested in applying for or where volunteered by you, e.g. a test result (whether positive or negative) or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate;
- In certain circumstances, video recordings of Candidates attending or participating in training or meetings where individuals have consented to the recording;
- Religious Beliefs in order to calculate entitlement to annual leave;
- Criminal conviction data
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Automatically collected information
- IP address;
- Usage information 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 e.g. Hays or Clients’ websites;
- Email engagement history 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 your referees choose to tell us about you;
- Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto, or is otherwise made available to us);
- Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us; and
- Additional information that you choose to tell us
- Any other information that you may provide to us including, for instance, details of your childcare or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information) and 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 collect your personal data?
We collect Candidate personal data in the following ways:
- Personal data that you, the Candidate, give to us;
- Personal data that we receive from other sources; 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 its services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
- There are numerous ways you can share your information with us. These may include:
- Entering your details on the Hays website or via an application form, as part of the registration process;
- Leaving a hard copy CV at a Hays recruitment event, job fair or office;
- Emailing your CV or other information to a Hays consultant or being interviewed by them;
- Applying for jobs through a job aggregator, which then redirects you to the Hays website;
- Entering your personal details into a Hays microsite; or
- Entering a competition through a social media channel such as Facebook or Twitter (or similar).
- The types of information that receive from you in this way include:
- Key identification and contact information;
- Education and employment information;
- Financial information;
- Special category information;
- Criminal conviction data, 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
- We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
- When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);
- Your referees may disclose personal information about you;
- Our Clients, Suppliers, other Candidates and our colleagues within Hays (e.g. in the context of them making a referral) may share personal information about you with us;
- If we receive your personal information from Facebook or Twitter, if you ‘like’ our Facebook page or ‘follow’ us on Twitter (or perform a similar interaction with us on any social media platform on which we have a presence); and
- If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.
- The types of information that we receive about you in this way include the information that others provide about you described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we collect automatically
- To the extent that you access our website or read or click on an email from us, 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. 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 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 Candidate data in five ways:
- Pre-recruitment Activities;
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
- In appropriate circumstances, we also use Candidate data for Profiling.
Pre-recruitment Activities
- When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services (usually via email), subject to any applicable laws and requirements.
- In order for us to do this, we may:
- Collect your personal data;
- Store your details (and update them when necessary) on our database so that we can contact you about our services;
- Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
- Review your information to work out whether and how our services might help you; and
- Contact you about our services.
- We've set out in more detail below various ways in which we will use and process your personal data for the purposes of determining whether our services would be beneficial to you, 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 Candidates 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to work out whether you might be interested in or benefit from recruitment services, including by: - collecting data from Candidates and other sources, such as LinkedIn - storing Candidates’ details on databases - assessing data against vacancies |
- Key identification and contact information - Education and employment information - Additional information that you choose to tell us - Information that others provide about you - Automatically collected information |
Legitimate interests, namely it is in our interests and your interests for us to assess whether you may be interested in or benefit from our recruitment services |
Collecting and processing your data in the course of reviewing your information to ascertain how Hays' recruitment services may assist |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests for us to identify how we can help you with your job search |
Collecting and processing your data in the course of communicating with you in relation to Hays' recruitment services |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to contact and correspond with you as part of providing you with our recruitment services |
Recruitment activities
- Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we will use and process your personal data for this purpose, 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 Candidates in any way – in fact, they help us to offer you a more tailored, efficient service. 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 in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
- When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Collecting and processing data in the course of and to the extent necessary to provide recruitment services to Candidates and facilitating the recruitment process including by: - Collecting data from Candidates and other sources, such as LinkedIn - Storing Candidates' details on database - Assessing data against vacancies - Sending Candidates' information to Clients, in order to apply for jobs or to assess eligibility for jobs - Enabling Candidates to submit CVs, apply online for jobs or to subscribe to alerts about jobs - Recording Candidates' question and answer sessions and/or video interviews to support our recruitment services (with the recordings being analysed for training/monitoring purposes and/or shared with Clients and viewed via a secure third party platform) - Making video recordings of Candidates' participation in training sessions or meetings for internal training/monitoring purposes and/or monitoring internal compliance standards |
- Key identification and contact information - Education and employment information - Additional information that you choose to tell us (e.g. information that you tell us in a recording) - Information that others provide about you - Video recording footage |
We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with our recruitment services and for you to receive them in order for us to function as a profit-making business, and to help you and other Candidates to find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request To the extent that we record a video of you, we will ask for your consent before we start recording but will rely on legitimate interests in relation to our use of the data for training/monitoring and for monitoring compliance standards |
Processing Candidates' data to facilitate payroll and invoicing processes |
- Key identification and contact information - Education and employment information - Financial information |
Legitimate interests, namely it is in our interests and your interests to: - ensure that our business runs smoothly, so that we can carry on providing services to Candidates like you - ensure that you are appropriately remunerated If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis |
Collecting and processing Candidates' data in the course of carrying out: - customer satisfaction surveys - Hays market research which we will use to inform our marketing materials and other informational materials such as whitepapers, reports and articles (e.g. our salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only |
- Key identification and contact information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to: - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary - gain an insight into the careers, goals and aspirations of the Candidates to whom we provide services in order to market our service offering to help differentiate us in a competitive marketplace |
Collecting and processing Candidates' data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support |
- Key identification and contact information - Additional information that you choose to tell us |
We will rely on legitimate interests, namely it is in our interests and your interests to: - address any issues that you have been experiencing - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis in relation to using your data in the course conducting communications relating to our services with you |
Processing Candidates' data to enable them to receive services ancillary to recruitment services, such as participation in: - specialist online training - interactive features of services - recruitment-related services via the Hays App |
- Key identification and contact information - Additional information that you choose to tell us - Information that others provide about you - Certain automatically collected information e.g. User choices and information about your use of these services |
We will rely on legitimate interests, namely it is in our interests and your interests to: - recommend and grant you with access to our specialist online training or some of our more interactive services as this might help with your job search - provide you with the best possible end-to-end service and enhance our service offering to you and to help differentiate us in a competitive marketplace If you have signed up to receive these ancillary services (either separately or because they form part of the recruitment services to which you have already signed up) or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request |
Processing Candidates' data in the course of carrying out Hays' obligations arising from any contracts entered into between Hays and third parties in relation to Candidates' recruitment, such as potential employers to whom we are committed to identifying the most suitable Candidates for roles in their organisations |
- Key identification and contact information - Education and employment information - Financial information - Information that others provide about you - Additional information that you choose to tell us |
We will rely on legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential employers so that we can help you find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is also necessary for the purposes of our contract with you (as well of the third party) |
Verifying details that a Candidate has provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws) |
- Key identification and contact information - Education and employment information - Criminal conviction data - Information that others provide about you - Additional information that you choose to tell us |
For criminal conviction data, we will obtain your explicit consent. For all other types of data: - we will rely on the legitimate interests legal basis, namely it is in our interests and your interests to verify that all of the information that you have provided to us is true and accurate and to obtain references about your prior conduct as part of the process of finding you employment - if you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that verifying details that you have provided or the requests that we need to make are necessary for the purposes of our contract with you. |
In certain jurisdictions, using a web-based video identity verification process to verify a Candidate's identity if we do not meet them in person and document this process |
- Key identification and contact information (including a copy of driving licence and/or passport/identity card) - Additional information that you choose to tell us - Video recording footage |
To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on the legitimate interests condition (it is in our legitimate interests to maintain internal compliance standards) in relation to our use of the data that we capture to verify your identity. For more information in relation to your jurisdiction, please click here |
Collecting and processing Candidate data in the course of carrying out assessment and development activities such as psychometric evaluations or skills tests - for more information in relation to your jurisdiction, please click here |
- Key identification and contact information - Additional information that you provide or choose to tell us during the evaluation/skills test (including in relation to your performance) |
Legitimate interests, namely it is in our interests and your interests for us to provide you with the services of our Assessment and Development departments, namely in relation to psychological assessment and research, assessment centres, competency management, reorganisation issues, management development, career development, mobility, outplacement, career transition and coaching. |
Marketing activities
- We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we will use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
- We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please click here.
- Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by informing one of our consultants that you are interested in our services, submitting a job application or CV, or registering a vacancy to be filled), and we are e-marketing or sending by text message other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. We will use your personal data to send you e-marketing materials with your ‘soft opt-in’ consent if we deem that it is in our legitimate interests to do so.
- For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time 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. Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Using Candidates' data to carry out marketing activities to promote our services through digital channels including in relation to: - marketing our full range of recruitment services (permanent, temporary, contract, outplacement, MSP programmes and RPO services) to you - sending Candidates details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to them - providing Candidates with information about certain discounts and offers that they are eligible for by virtue of their relationship with Hays |
- Key identification and contact information - Automatically collected information |
If we have obtained your contact details from an occasion when you previously engaged with us and we are e-marketing other recruitment-related services of our own, we will rely on soft opt-in consent if we consider that the legitimate interests legal basis applies, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in In all other circumstances, we will obtain your opt-in consent |
Collection of data via cookies or tracking pixels and use of data to show users Hays adverts and other content on other websites, for example, Facebook |
- Key identification and contact information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy) Even where you have turned off advertising cookies, it is still possible that you may see a Hays advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience Please note that if you access Hays' services across multiple devices, you may need to adjust your settings (e.g. if you want to turn off advertising cookies) via the Cookie Preferences link on each of your devices |
Lookalike targeting and other data driven marketing: providing lists of certain Candidates' data to Facebook and Google to enable them to find an audience of people with similar characteristics or demographics to these Candidates (which will not include these Candidates) for Hays' marketing purposes. Facebook's policy is to irreversibly hash such lists prior to use, match the hashed data against their own customers, generate the lookalike audience, then delete the original list and use it for no other purpose. We will not have access to the identity of anyone in the lookalike audience, unless they choose to click on the advertisements. |
- Key identification and contact information - Automatically collected information (advertising identifiers) |
We will obtain your opt-in consent for the collection of advertising identifiers via the Cookie Preferences link on our website We will share these advertising identifiers with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent in which case we will obtain such consent via our consent management tool |
Displaying excerpts from Candidates' profiles for promotional purposes on Hays' website(s) to provide examples of success stories |
- Key identification and contact information - Education and employment information - Additional information that choose to tell us (we may ask you for additional details for the purposes of the story that we tell about you) |
We will always ask for your explicit consent before featuring you in this way on the website |
Use of Candidates' data in the course of making service and marketing communications via WhatsApp |
- Key identification and contact information - Automatically collected information |
We will ensure that you have opted-in (and therefore provided your consent) through one of a number of channels: - when you signing up to WhatsApp job alerts on the website - submitting an opt-in message direct to one of our WhatsApp channels - clicking through on a sign-up button on an invite email. |
Special category data
- We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities and so we will process certain sensitive/special category data about you to facilitate this. Where appropriate and in accordance with local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.
- We will collect other sensitive/special category personal data about you such as health-related information or religious affiliation if this is appropriate in accordance with local laws: Article 9(2)(b) of the GDPR allows us to do this where the processing is “necessary for the purposes of carrying out the obligations and exercising our or your specific rights… in the field of employment and social security and social protection law”, as long as this is allowed by law.
- We may also collect details of any criminal convictions if appropriate in accordance with local laws which may require your consent. If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so by referring to the section entitled “How you can access, amend or take back the personal data you have given us” in the General Privacy Information section of this Privacy Policy.
- Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive/special category data. For more information in relation to your jurisdiction, please click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Collecting and analysing Candidates' data in order to assess and ensure our compliance with equal opportunities obligations | Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) keeping under review the existence or absence of equality of opportunity or treatment between groups of people and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Sharing Candidates' data (that has been collected to assess and ensure our compliance with equal opportunities obligations) with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes | Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information | We will obtain your explicit consent before we share your data in this way |
Processing medical history/health-related data to make reasonable adjustments during the recruitment process | Medical history/physical or mental health-related data |
We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. to assess the working capacity of an employee or potential employee for an employer) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing health-related data to when we need to use or offer occupational health to Candidates in the context of certain types of roles (e.g. teaching, nursing or night work) | Medical history/physical or mental health-related data |
We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. the provision of health care or treatment) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing health-related information arising from or in connection with the COVID-19 or other pandemics where this is required for a role that you are interested in applying for or where volunteered by you | Test results (whether positive or negative), or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate |
We rely on legitimate interests, namely it is in our and your interests for us to collect and share your health-related information if this is required for a role that you are interested in applying for We may also rely on the vital interests and the public interest lawful bases, namely to protect against serious cross-border threats to health If local law requires us to obtain your consent, we will do so |
Processing criminal convictions data when carrying out background checks |
Details of any criminal convictions disclosed by Candidate on the Candidate Application Form Details of any criminal convictions obtained via background checks that we are required to carry out where this is necessary for us to comply with our legal obligations in connection with a Candidate's search for work (e.g. if we put a Candidate forward for certain roles which require a certain type of background check to be carried out) |
We will obtain your explicit consent in the Candidate Application Form though where local laws allow us to do so, we may need to request a Disclosure and Barring Service Check (or equivalent applicable check in your jurisdiction) without your consent where this is necessary for us to comply with our legal obligations in connection with your search for work |
Processing certain types of Candidate data in order to calculate entitlement to annual leave |
- Medical history/health-related data - Religious affiliation |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
Processing the sensitive/special category personal data of individuals connected with Candidates, for example: - where a Candidate discloses this to us in the course of providing next-of-kin details - to allow the relevant Candidate to access certain benefits |
Details of sexual orientation, and physical or mental health, including disability-related information |
We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so |
To help us to establish, exercise or defend legal claims
- Sometimes it will be necessary for us to process personal data in reliance on the legitimate interests legal basis and, where appropriate and in accordance with local laws and requirements, special category data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
- This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Preserving, sharing and otherwise processing Candidate data to establish, exercise or defend legal claims |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Education and employment information Special category information Criminal conviction data Financial information Automatically collected information Information that others provide about you Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes In the unlikely event that we need to process any special category information or criminal conviction data for this purpose, we will only do so where local law allows us to process such data to establish, exercise or defend legal claims |
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.
- We also sometimes use automated systems such as filtering tools, or occasionally more complex tools which use an element of artificial intelligence, such as algorithms or machine learning (including those provided by third parties), to help us quickly, efficiently and more accurately to analyse data we have about you and other Candidates, as well as data we hold on our Clients' needs, and this ultimately helps us to make decisions based on this data. This can include applying tools which use algorithms (such as filtering tools or machine learning) to Candidate personal data in order to help us come up with the best possible shortlist for a particular role. Such technology should reduce significantly the amount of time needed to consider when Candidates might be the best fit for relevant jobs. This should in turn make the recruitment process much more efficient and effective, which, we hope, will improve your overall experience with us.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that we can show Candidates both targeted and personalised content. This will include: - personalising Candidates' website experience, including in relation to the roles that are brought to their attention when visiting the website - making recommendations for editorial content that we think may be of interest to Candidates (e.g. reports about developments in their industry) - personalising the marketing content that Candidates receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Candidates engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed |
- Key identification and contact information - Education and employment information - Automatically collected information - Additional information that you choose to tell us More specifically, this will include: - Personal information and information about the Candidate's job search (i.e. as submitted via form or pulled through from our Systems) - Details of Candidates' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) - Location data - either inferred from jobs, IP, or application history, or system stored data - Digital identifiers - IP address, personalisation cookies - Website browsing data, form submission data and email engagement data - Marketing preferences |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices. Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: - increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the Hays websites and email campaigns - increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you - encourage you to come back to our website by making this most helpful experience possible - reduce website bounce rate - increase email engagement rate (i.e. the frequency with which users click through) |
We may capture and analyse Candidates' web-based behaviours using various items of data e.g. number of job ads read/applied for online, number and type of articles read, number of web visits made, membership of “talent pools”/segments – see below) in order to award a Candidate a weighted “approachability score” with a view to providing insights into Candidates' needs and to allow Hays to follow up where needed Consultants will use these scores as part of the shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Candidate, which will serve to supplement other data that Hays holds about the Candidate Our collection of web-based data will rely on the personalisation cookies/pixels that we place on your device as part of the personalisation activities as described above |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device However, please note that we may still carry out engagement scoring activities even if a personalisation cookie is not placed on your device (e.g. we may consider the information that we already hold about you on our Systems with a view to allocating you an engagement score even if you have opted out of the personalisation cookie) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to allocating you an engagement score and our subsequent use of this score We consider that it is in our legitimate interests to allocate you with an engagement score in order to help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you
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We may use the data that we collect via personalisation cookies/pixels e.g. web-based behaviours such as details of Candidates' interactions with the website (e.g. applications, web page visits), to enrich the Candidate data and existing profiles about them that we already hold on our Systems |
- Key identification and contact information - Education and employment information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to using data that we collect about you to enrich your existing profile on our Systems We consider that it is in our legitimate interests to enrich the data that we hold about you to help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you |
Analysing Candidates' data by continuously tracking and monitoring their experience and account activity in order to profile them and allocate them to “talent pools” based on their attributes and behaviours (e.g. previous roles, skills, industry experience, location, when a Candidate is willing to work) Talent pools are used as a means of managing the Candidate database, placing Candidates in roles and marketing to Candidates The assignment of Candidates to talent pools is a fully automated process and can involve the use of bots |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to use profiling methods to place you and your Candidate profile into groups or segments with other Candidates, based on your interests, habits, attributes and/or preferences in order to: - help us to optimise the matching of Candidate profiles to roles and improve the effectiveness and efficiency of the recruitment cycle - allow us to keep track of whether we have enough suitable Candidates to fulfil our business needs and those of our Clients at all times - help our consultants to make decisions in relation to suggesting relevant roles and sending relevant communications to you |
We may use profiling methods in relation to Candidates' data so that we can: - place them and other suitable Candidates on shortlists for particular roles based on prescribed criteria, which will allow our consultants to identify the most appropriate Candidates for roles in the most efficient manner efficiently; and - recommend roles based on how a Candidate's interests, habits, attributes and/or preferences, rank in comparison to other Candidates Our intention is for any such activities (which might involve using automated processes to profile, select, screen, rank, grade, shortlist and/or put forward Candidates for roles) to complement rather than completely replace the activity of our consultants |
- Key identification and contact information - Education and employment information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to use profiling methods to place you and your Candidate profile into groups or segments with other Candidates, based on your interests, habits, attributes and/or preferences in order to: - help us to optimise the matching of Candidate profiles to roles and improve the effectiveness and efficiency of the recruitment cycle - help our consultants to make decisions in relation to suggesting relevant roles to you If these shortlisting and ranking activities amount to Automated Decision Making for the purposes of Article 22 of the GDPR, we will only conduct these activities where we deem this to be necessary for the completion of pre-contractual steps taken at your request. We think it is reasonable to assume that, as a Candidate, you are hoping to enter into an employment contract, and that by using our services you are asking us to take the necessary steps for this purpose. Such steps might include, for example, checking you meet certain requirements for a particular role. If the role is very popular, we may have to check the eligibility of a large number of potential Candidates – we may therefore use automated decision making to filter this pool of Candidates down to a more manageable number. |
Compliance with a legal obligation
- In some circumstances, we will use your personal data to comply with our legal obligations. Article 6(1)(c) of the GDPR says that we can process your data where it “is necessary for compliance with a legal obligation to which (we) are subject”.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Accessing, preserving and disclosing Candidates' data if there is a valid legal request from a regulator, law enforcement, authority or if we otherwise have a legal duty to do so |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Automatically collected information - Education and employment information - Information that others provide about you |
Compliance with a legal obligation including where: - we are in receipt of a court order to disclose information for the purposes of court proceedings in the context of civil and commercial matters - we are compelled by law enforcement agencies to provide data in relation to a criminal investigation - we need to comply with our obligations under consumer law, for example competition legislation - we need to comply with our obligations under companies legislation and tax law, for example, to provide details of your remuneration and tax paid - we need to comply with our obligations under data protection laws - we need to comply with our obligations under employment laws (e.g. those which require us to track the number of hours you have worked) |
Preserving and sharing Candidates' data with others including law enforcement agencies and to respond to legal requests when we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Automatically collected information - Information that others provide about you |
Even where we are not under a legal obligation to process your data, we will, under certain circumstances, have a legitimate interest in cooperating with law enforcement agencies and other bodies in order to assist, for example, with the prevention and detection of crime |
Processing Candidates' data when verifying documents and information requested from and provided by Candidates to prove that they have the right to work in a particular jurisdiction |
- Key identification and contact information (e.g. a copy of your passport and proof of address) - Education and employment information (e.g. immigration status and work permit if applicable) - Financial information (e.g. social security number or equivalent in your country) |
We will process your data where this is necessary for us to comply with our legal obligations in relation to ensuring that you have the right to work in a particular jurisdiction |
Sharing of data
- We will share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we will also share your information with any of our group companies and associated third parties such as our service providers and selected job aggregators where we feel this will help us to provide you with the best possible service and maximise your chances of getting what you want.
- 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Disclosing Candidates' data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area for the purposes listed in the preceding tables |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Financial information - Education and employment information - Special category data - Criminal conviction data - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
- The disclosure is necessary (e.g. to potential employers) to conclude and perform any contracts that we have entered into with you (see section entitled Recruitment Activities above) - The disclosure (e.g. to tax, audit, or other authorities) is necessary for the compliance with a legal obligation to which we are subject (see section entitled Compliance with a legal obligation above) - The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims - We have obtained your consent (e.g. when we share your special category data with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes - The disclosure is necessary for health and social care purposes (e.g. to an occupational health specialist to enable the provision of support during the recruitment process if an Candidate suffers from a health condition or disability) - The disclosure is necessary for carrying out the obligations and exercising Hays' specific rights in the field of employment and social security and social protection law (e.g. on an intragroup basis when assessing and effecting your entitlement to annual leave/certain benefits) - The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above) |
This section of the Privacy Policy applies to Temporary Workers.
Temporary Workers include 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 click here. Temp Relationship means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
What kind of personal information do we collect?
If we employ or engage you as a Temporary Worker directly, we will, depending on the relevant circumstances and applicable local laws and requirements, collect some or all of the information listed below (in addition to the data collected about Candidates) in order to ensure that our Temp Relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our Clients, as part of our Temp Relationship and our duties to third parties such as tax authorities and government agencies. 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:
- Temporary worker information
- Staff number/social security number/other identifier;
- Location of your workplace at the Client;
- Details of any complaints, whether brought by or against you or in which you are or have been otherwise involved;
- Details of any leave you take or request during our Temp Relationship;
- Details of travel undertaken;
- Details of resident/work permit;
- Where applicable:
- Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved; and
- Information about your performance in your role during our Temp Relationship, including details of any bonuses or promotions you receive performance assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise; and
- Special category information
- Details of any sickness absence including health-related information.
Please note that the above list of categories of personal data we collect is not exhaustive.
A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Some, for example your social security number (or equivalent) are required by statute or other laws. Other items may simply be needed to ensure that our Temp Relationship can run smoothly, or to run our business.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our Temp Relationship.
How do we collect you personal data?
If we employ or engage you as a Temporary Worker directly, we collect your data (in addition to the data already collected about Candidates) in the following ways:
- Personal data that you give to us; and
- Personal data that we receive from other sources.
Below are some more details about each of these methods.
Personal data you give to us
Hays needs to know certain information about you in order to fulfil our obligations to you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are both fulfilling our obligations to others. This information will enable us to operate a usual Temp Relationship, along with all that entails.
There are numerous ways that you can share your information with us in addition to the information you share as a Candidate. Where appropriate and in accordance with any local laws and requirements, these may include:
- when you complete registration forms at the beginning of our Temp Relationship; or
- in meetings or communications with your consultant, our HR team or other colleagues.
The types of information that we receive from you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we receive from other sources
We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- if you were referred to us through a recruitment agency or other work agencies, they may have shared personal information about you with us;
- information obtained about you from third party service providers who undertook background checks about you on our behalf at the start of our Temp Relationship;
- your colleagues may share personal information about you with us;
- medical professionals may (in appropriate and limited circumstances) share personal information about you with us;
- your pension and benefits providers may share relevant personal information about you with us; and
- other third parties like your local tax authority may share your personal data with us.
The types of information that we receive about you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
How do we use your personal data?
If we employ or engage you as a Temporary Worker directly, we use your data for the following purposes:
- To ensure the smooth running of our Temp Relationship, including all of the activities that need to be undertaken in a usual relationship of that type, such as:
- facilitating payroll and invoicing processes, if relevant to your jurisdiction;
- determining the terms on which you work during your Temp Relationship;
- keeping a record of any promotions, salary rises or bonuses you are awarded; and
- Assessing your performance.
Some more detailed information about the way in which your data is processed can be found in the Recruits Privacy Policy. For example, during the on-boarding process with Hays, Temporary Workers will be treated in a similar way as recruits for Hays roles and their personal data during the recruitment process for such roles will be processed in the ways described in the Recruits Privacy Policy. Depending on the applicable local laws, we appreciate that you are not a 'Recruit' in the sense of that Policy but given that we use the data in a similar way, for the same purposes, we thought you wouldn’t mind having a quick look at that policy if you were interested in a greater level of detail.
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 click here.
Temp Relationship Activities
- We've listed below various ways in which we will use and process your personal data in connection with our Temp Relationship, 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 it is necessary for us to carry out our obligations under a contract that we have entered into with you or if we deem it necessary to do so for our legitimate interests.
- Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
- 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 Temporary Workers in any way – in fact, they help us to offer you a more tailored, efficient service. 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.
- When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to facilitate the Temp Relationship, including by: - Facilitating payroll and invoicing processes - Determining the terms on which Temporary Workers work during the Temp Relationship - Storing Temporary Worker details on database (including start dates and duration of the length of assignment, hours worked during assignments, and (in some jurisdictions) records of any promotions, salary rises or bonuses awarded) - Assessing Temporary Workers' performance - Giving Temporary Workers feedback in relation to assignments - Managing absences |
- Temporary worker information - Special category information |
If you have entered into a Temp Relationship with us, we will rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract that we have entered into with you We will otherwise rely on legitimate interests, namely it is in our interests and your interests for us to facilitate the Temp Relationship If we need to process your special category data (e.g. details of any sickness absence including health-related information), we will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes and local laws allow us to process your data in this way without obtaining your consent. If local law requires us to obtain your consent, we will do so. |
Sharing of data
- If we employ or engage you directly as a Temporary Worker, we may share your personal data with a number of additional parties in order to ensure the smooth running of our Temp Relationship. For example, we may share your personal data with appropriate colleagues within Hays (this may include colleagues in overseas offices), with a Client and, if appropriate, medical professionals such as your GP or an occupational health specialist (for instance, for the purpose of any work adjustment assessments if applicable).
- We will generally rely on the same legal bases referred to in the section addressing Temp Relationship Activities above depending on the context.
- 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 click here.
This section of the Privacy Policy applies to Temporary Workers.
Temporary Workers include 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 click here. Temp Relationship means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
What kind of personal information do we collect?
If we employ or engage you as a Temporary Worker directly, we will, depending on the relevant circumstances and applicable local laws and requirements, collect some or all of the information listed below (in addition to the data collected about Candidates) in order to ensure that our Temp Relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our Clients, as part of our Temp Relationship and our duties to third parties such as tax authorities and government agencies. 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:
- Temporary worker information
- Staff number/social security number/other identifier;
- Location of your workplace at the Client;
- Details of any complaints, whether brought by or against you or in which you are or have been otherwise involved;
- Details of any leave you take or request during our Temp Relationship;
- Details of travel undertaken;
- Details of resident/work permit;
- Where applicable:
- Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved; and
- Information about your performance in your role during our Temp Relationship, including details of any bonuses or promotions you receive performance assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise; and
- Special category information
- Details of any sickness absence including health-related information.
Please note that the above list of categories of personal data we collect is not exhaustive.
A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Some, for example your social security number (or equivalent) are required by statute or other laws. Other items may simply be needed to ensure that our Temp Relationship can run smoothly, or to run our business.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our Temp Relationship.
How do we collect you personal data?
If we employ or engage you as a Temporary Worker directly, we collect your data (in addition to the data already collected about Candidates) in the following ways:
- Personal data that you give to us; and
- Personal data that we receive from other sources.
Below are some more details about each of these methods.
Personal data you give to us
Hays needs to know certain information about you in order to fulfil our obligations to you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are both fulfilling our obligations to others. This information will enable us to operate a usual Temp Relationship, along with all that entails.
There are numerous ways that you can share your information with us in addition to the information you share as a Candidate. Where appropriate and in accordance with any local laws and requirements, these may include:
- when you complete registration forms at the beginning of our Temp Relationship; or
- in meetings or communications with your consultant, our HR team or other colleagues.
The types of information that we receive from you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we receive from other sources
We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- if you were referred to us through a recruitment agency or other work agencies, they may have shared personal information about you with us;
- information obtained about you from third party service providers who undertook background checks about you on our behalf at the start of our Temp Relationship;
- your colleagues may share personal information about you with us;
- medical professionals may (in appropriate and limited circumstances) share personal information about you with us;
- your pension and benefits providers may share relevant personal information about you with us; and
- other third parties like your local tax authority may share your personal data with us.
The types of information that we receive about you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
How do we use your personal data?
If we employ or engage you as a Temporary Worker directly, we use your data for the following purposes:
- To ensure the smooth running of our Temp Relationship, including all of the activities that need to be undertaken in a usual relationship of that type, such as:
- facilitating payroll and invoicing processes, if relevant to your jurisdiction;
- determining the terms on which you work during your Temp Relationship;
- keeping a record of any promotions, salary rises or bonuses you are awarded; and
- Assessing your performance.
Some more detailed information about the way in which your data is processed can be found in the Recruits Privacy Policy. For example, during the on-boarding process with Hays, Temporary Workers will be treated in a similar way as recruits for Hays roles and their personal data during the recruitment process for such roles will be processed in the ways described in the Recruits Privacy Policy. Depending on the applicable local laws, we appreciate that you are not a 'Recruit' in the sense of that Policy but given that we use the data in a similar way, for the same purposes, we thought you wouldn’t mind having a quick look at that policy if you were interested in a greater level of detail.
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 click here.
Temp Relationship Activities
- We've listed below various ways in which we will use and process your personal data in connection with our Temp Relationship, 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 it is necessary for us to carry out our obligations under a contract that we have entered into with you or if we deem it necessary to do so for our legitimate interests.
- Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
- 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 Temporary Workers in any way – in fact, they help us to offer you a more tailored, efficient service. 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.
- When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to facilitate the Temp Relationship, including by: - Facilitating payroll and invoicing processes - Determining the terms on which Temporary Workers work during the Temp Relationship - Storing Temporary Worker details on database (including start dates and duration of the length of assignment, hours worked during assignments, and (in some jurisdictions) records of any promotions, salary rises or bonuses awarded) - Assessing Temporary Workers' performance - Giving Temporary Workers feedback in relation to assignments - Managing absences |
- Temporary worker information - Special category information |
If you have entered into a Temp Relationship with us, we will rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract that we have entered into with you We will otherwise rely on legitimate interests, namely it is in our interests and your interests for us to facilitate the Temp Relationship If we need to process your special category data (e.g. details of any sickness absence including health-related information), we will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes and local laws allow us to process your data in this way without obtaining your consent. If local law requires us to obtain your consent, we will do so. |
Sharing of data
- If we employ or engage you directly as a Temporary Worker, we may share your personal data with a number of additional parties in order to ensure the smooth running of our Temp Relationship. For example, we may share your personal data with appropriate colleagues within Hays (this may include colleagues in overseas offices), with a Client and, if appropriate, medical professionals such as your GP or an occupational health specialist (for instance, for the purpose of any work adjustment assessments if applicable).
- We will generally rely on the same legal bases referred to in the section addressing Temp Relationship Activities above depending on the context.
- 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 click here.
This section of the Privacy Policy applies to Clients.
Clients include 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, 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to reach out to Clients about our services, including by: - Storing Client details (and updating them when necessary) on Hays' database, so that Hays can contact Clients in relation to our services; - Keeping records of Hays' conversations and meetings with Clients, so that Hays can provide targeted services to Clients |
- Key identification and contact information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests: - for us to reach out to you about our services in order to provide you or your organisation with suitable Candidates, an MSP programme; RPO services and/or consultancy and advisory services |
Collecting and processing data in the course of and to the extent necessary to: - provide services to colleagues/employees of Hays' Clients - make video recordings of Clients' (and colleagues/employees of Clients) participation in training sessions or meetings for internal training/monitoring purposes and/or maintaining internal compliance standards |
- Key identification and contact information - Additional information that you choose to tell us - Video recording footage |
Legitimate interests, namely it is in our interests and your interests: - for us to, in certain circumstances, reach out to your colleagues/employees about our services, such as training courses To the extent that we record a video of you, we will ask for your consent before we start recording, but will rely on legitimate interests in relation to our use of the data for training/monitoring and for maintaining compliance standards |
Collecting and processing Client data in the course of carrying out: - customer satisfaction surveys - Hays market research which Hays will use to inform its marketing materials and other informational materials, such as whitepapers, reports and articles (e.g. Hays' salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only |
- Key identification and contact information - Automatically collected information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to: - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary |
Processing Client data in the course of carrying out Hays' obligations arising from any contracts entered into between Hays and third parties in relation to recruitment, such as potential Candidates who Hays identifies as suitable for a role in a Client organisation |
- Key identification and contact information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential Candidates, so that we can help you find suitable employees |
In certain jurisdictions, using a web-based video identity verification process to verify a Client's identity and document this process |
- Key identification and contact information (including a copy of driving licence and/or passport/identity card) - Additional information that you choose to tell us - Video recording footage |
To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on compliance with a legal obligation to the extent that we are compelled by applicable law to verify your identity (e.g. in the context of payments services) For more information in relation to your jurisdiction, please click here |
Collecting and processing Client data in the course of obtaining Candidate references from Clients, and sharing this data with third parties who require these references where appropriate |
- Key identification and contact information - Additional information that you choose to tell us - Reference about a Candidate |
Legitimate interests, namely it is in our interests to obtain Candidate references in the course of carrying out our services, and to verify details they have provided |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Processing Client data for the purpose of targeting appropriate marketing campaigns for Hays' services |
- Key identification and contact information - Automatically collected information |
Legitimate interests, namely if we wish to reach out to you to tell you about our services, and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in. |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that Hays can show Clients both targeted and personalised content This will include: - personalising Clients' website experience, including in relation to the roles that are brought to their attention when visiting the website - making recommendations for editorial content that we think may be of interest to Clients (e.g. reports about developments in the relevant industry) - personalising the marketing content that Clients receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Clients engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed. Hays will use this information to understand what they may be interested in and tailor what it shows and sends to them accordingly |
- Key identification and contact information - Automatically collected information More specifically, this will include: - Personal information and information about the Client's job search (i.e. as submitted via form or pulled through from our Systems) - Details of Clients' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) - Location data - either inferred from jobs, IP, or application history, or system stored data - Digital identifiers - IP address, personalisation cookies - Website browsing data, form submission data and email engagement data - Marketing preferences |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality. If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: - increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the Hays websites and email campaigns - increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you - encourage you to come back to our website by making this most helpful experience possible - reduce website bounce rate - increase email engagement rate (i.e. the frequency with which users click through) |
Hays may capture and analyse Clients' web-based behaviours using various items of data e.g. number of web visits made, number of candidates searched) in order to award a Client a weighted “approachability score” with a view to providing insights into Clients' needs and to allow Hays to follow up where needed Consultants will use these scores as part of the shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Client (and what to show them), which will serve to supplement other data that Hays holds about the Client Hays collection of web-based data will rely on the personalisation cookies/pixels that it places on Clients' devices as part of the personalisation activities described above |
- Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices However, please note that we may still carry out engagement scoring activities even if a personalisation cookie is not placed on your device (e.g. we may consider the data that we already hold on our systems about you with a view to allocating you an engagement score even if you have opted out of the personalisation cookie) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to allocating you an engagement score and our subsequent use of this score We consider that it is in our legitimate interests to allocate you with an engagement score in order to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you |
Hays may use the data that it collects via personalisation cookies/pixels e.g. web-based behaviours such as details of Clients' interactions with the website (e.g. applications, web page visits), to enrich the Client data and existing profiles about them that Hays already holds on its Systems |
- Key identification and contact information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device
Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to using data that we collect about you to enrich your existing profile on our Systems We consider that it is in our legitimate interests to enrich the data that we hold about you to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Disclosing Clients' data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area for the purposes listed in the preceding tables |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
- The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims - The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above) |
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.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Preserving, sharing and otherwise processing Client data to establish, exercise or defend legal claims |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes |
This section of the Privacy Policy applies to Clients.
Clients include 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, 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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to reach out to Clients about our services, including by: - Storing Client details (and updating them when necessary) on Hays' database, so that Hays can contact Clients in relation to our services; - Keeping records of Hays' conversations and meetings with Clients, so that Hays can provide targeted services to Clients |
- Key identification and contact information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests: - for us to reach out to you about our services in order to provide you or your organisation with suitable Candidates, an MSP programme; RPO services and/or consultancy and advisory services |
Collecting and processing data in the course of and to the extent necessary to: - provide services to colleagues/employees of Hays' Clients - make video recordings of Clients' (and colleagues/employees of Clients) participation in training sessions or meetings for internal training/monitoring purposes and/or maintaining internal compliance standards |
- Key identification and contact information - Additional information that you choose to tell us - Video recording footage |
Legitimate interests, namely it is in our interests and your interests: - for us to, in certain circumstances, reach out to your colleagues/employees about our services, such as training courses To the extent that we record a video of you, we will ask for your consent before we start recording, but will rely on legitimate interests in relation to our use of the data for training/monitoring and for maintaining compliance standards |
Collecting and processing Client data in the course of carrying out: - customer satisfaction surveys - Hays market research which Hays will use to inform its marketing materials and other informational materials, such as whitepapers, reports and articles (e.g. Hays' salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only |
- Key identification and contact information - Automatically collected information - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to: - improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary |
Processing Client data in the course of carrying out Hays' obligations arising from any contracts entered into between Hays and third parties in relation to recruitment, such as potential Candidates who Hays identifies as suitable for a role in a Client organisation |
- Key identification and contact information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential Candidates, so that we can help you find suitable employees |
In certain jurisdictions, using a web-based video identity verification process to verify a Client's identity and document this process |
- Key identification and contact information (including a copy of driving licence and/or passport/identity card) - Additional information that you choose to tell us - Video recording footage |
To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on compliance with a legal obligation to the extent that we are compelled by applicable law to verify your identity (e.g. in the context of payments services) For more information in relation to your jurisdiction, please click here |
Collecting and processing Client data in the course of obtaining Candidate references from Clients, and sharing this data with third parties who require these references where appropriate |
- Key identification and contact information - Additional information that you choose to tell us - Reference about a Candidate |
Legitimate interests, namely it is in our interests to obtain Candidate references in the course of carrying out our services, and to verify details they have provided |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Processing Client data for the purpose of targeting appropriate marketing campaigns for Hays' services |
- Key identification and contact information - Automatically collected information |
Legitimate interests, namely if we wish to reach out to you to tell you about our services, and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in. |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that Hays can show Clients both targeted and personalised content This will include: - personalising Clients' website experience, including in relation to the roles that are brought to their attention when visiting the website - making recommendations for editorial content that we think may be of interest to Clients (e.g. reports about developments in the relevant industry) - personalising the marketing content that Clients receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Clients engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed. Hays will use this information to understand what they may be interested in and tailor what it shows and sends to them accordingly |
- Key identification and contact information - Automatically collected information More specifically, this will include: - Personal information and information about the Client's job search (i.e. as submitted via form or pulled through from our Systems) - Details of Clients' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) - Location data - either inferred from jobs, IP, or application history, or system stored data - Digital identifiers - IP address, personalisation cookies - Website browsing data, form submission data and email engagement data - Marketing preferences |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality. If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: - increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the Hays websites and email campaigns - increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you - encourage you to come back to our website by making this most helpful experience possible - reduce website bounce rate - increase email engagement rate (i.e. the frequency with which users click through) |
Hays may capture and analyse Clients' web-based behaviours using various items of data e.g. number of web visits made, number of candidates searched) in order to award a Client a weighted “approachability score” with a view to providing insights into Clients' needs and to allow Hays to follow up where needed Consultants will use these scores as part of the shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Client (and what to show them), which will serve to supplement other data that Hays holds about the Client Hays collection of web-based data will rely on the personalisation cookies/pixels that it places on Clients' devices as part of the personalisation activities described above |
- Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices However, please note that we may still carry out engagement scoring activities even if a personalisation cookie is not placed on your device (e.g. we may consider the data that we already hold on our systems about you with a view to allocating you an engagement score even if you have opted out of the personalisation cookie) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to allocating you an engagement score and our subsequent use of this score We consider that it is in our legitimate interests to allocate you with an engagement score in order to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you |
Hays may use the data that it collects via personalisation cookies/pixels e.g. web-based behaviours such as details of Clients' interactions with the website (e.g. applications, web page visits), to enrich the Client data and existing profiles about them that Hays already holds on its Systems |
- Key identification and contact information - Automatically collected information |
We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device
Please note that if you access Hays' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to using data that we collect about you to enrich your existing profile on our Systems We consider that it is in our legitimate interests to enrich the data that we hold about you to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you |
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 click here.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Disclosing Clients' data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area for the purposes listed in the preceding tables |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
- The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims - The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above) |
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.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
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Preserving, sharing and otherwise processing Client data to establish, exercise or defend legal claims |
The actual information used depends on the factual circumstances, but could include any of the following: - Key identification and contact information - Automatically collected information - Information that others provide about you - Additional information that you choose to tell us |
Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes |