General
privacy policy

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.

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.

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.

        
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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

This section of the Privacy Policy applies to People Whose Data we receive from Candidates and Hays' Staff. These may include emergency contacts and referees. We will only contact them in appropriate circumstances.

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

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

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

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

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

How do we use your personal data?

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

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

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

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

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

Sharing of data

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

This section of the Privacy Policy applies to Website Users.

Website Users include any individual who accesses any of the Hays websites or any of the Hays mobile applications (apps).

What kind of personal information do we collect?

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

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

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

How do we collect your personal data?

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

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

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

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

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

How do we use your personal data?

We use your data to:

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

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

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

Sharing of data

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

This section of the Privacy Policy applies to Staff Alumni. 

Staff Alumni include former members of Staff who have expressed their wish to remain part of Hays' alumni network and to use Hays' alumni portal.

What kind of personal information do we collect?

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

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

How do we collect your personal data?

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

How do we use your personal data?

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

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

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

Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.” If you are not happy about this, you have the right to object and you can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy. 

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

Sharing of data

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

This section of the Privacy Policy applies to Visitors. 

Visitors include individuals who visit our premises but who are not members of our Staff.

What kind of personal information do we collect?

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

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

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

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

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

How do we collect your personal data?

We collect Visitor personal data in the following ways: 

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

Personal data you give to us 

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

Hays will usually collect this information from you upon your arrival at our premises. 
The types of information that receive from you in this way include:

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

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

Personal data we collect automatically

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

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

How do we use your personal data?

We generally use Visitor data for Visitor Management purposes.

Visitor Management

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

Sharing of data

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

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

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

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

Country-specific legal requirement - Jurisdiction Germany

Referees

Where a referee is being asked to give a reference based on their professional experience of a Candidate, we will not use the referee's details to reach out to get in touch in the alternative capacity as a Client unless we are explicitly asked to do so by the referee.

Prospective candidate data

In relation to the ways in which we collect your data, if we collect your personal data from a third party online platform/website that prohibits data scraping in its terms of use, we will take this into account in determining whether to collect your data from such sources. 

We use Prospective Candidate 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. In Germany, we do this not via email, but via phone or messages via a the job network (unless you have consented to be contacted via email).

Use of sensitive or special category candidate data

Race or ethnic background

In Germany, we collect details of our Candidates' religious affiliation to facilitate our payroll process. As this is a necessary legal requirement, we will not seek your explicit consent to process this information.

DSARs

In accordance with local law, we have the right to refuse to respond to your DSAR in circumstances where your data are only being held: (i) pursuant to a legal obligation to retain them; or (ii) for the purposes of monitoring data protection or safeguarding data, in each case where providing the information would require a disproportionate effort, and appropriate technical and organisational measures make processing for other purposes impossible. 

Requests to erase your data

Where your data are not being processed in an automated way, unless your data are being processed unlawfully, we will not be required to erase your data if erasure would be impossible or would involve a disproportionate effort due to the specific method of storage, provided that we think your interest in erasure is minimal.

Where your data are being processed in an automated way, we will also have the right to refuse to erase your data if we have reason to believe that such erasure will adversely affect your legitimate interests, or if such erasure would cause us to breach any legal obligation to retain your data for a specific period. Instead, in these circumstances, processing of your data will be restricted in the particular ways envisaged by the GDPR. 

Marketing, retargeting and market research purposes

Soft-opt-In

As described in the main body of our Privacy Policy, we are entitled to rely on "soft-opt-in" consent in respect of certain marketing messages that we wish to send to you. The conditions that apply to our using of soft-opt-in consent are that: (i) we have obtained your email address in connection with the sale of goods or services; (ii) we use that address only for direct advertising of our own (or substantially similar) services; (iii) you have not objected to this use; and (iv) we clearly advise you, in each such communication, of your right to opt-out.

Opt-In

In all other e-marketing circumstances, we are required to obtain your specific "opt-in" consent and we are required to keep records of such consent having been received. To comply with our obligations under the Act Against Unfair Competition, we undertake what is commonly known as the "double-opt-in" consent procedure, which is where we first ask you to opt-in to receive e-marketing, and we then send you an email asking you to confirm that you have given your consent. We may only add you to our marketing list once we have received this second email confirmation.

Retargeting

When you consented to the transfer of data to our advertising partners we send your data (e.g. your email address, your name, your phone number) in an encrypted and pseudonymised way (so called “hashed”) to our advertising partners (for a list of our advertising partners, see below). They compare this data with the data they already process about you and if they match, the partners enable us to run targeted advertising on those matches or on similar groups of people like you, which means the partners display on their platforms Hays advertising which are specially designed for you or for people like you. After the creation of the matches, your encrypted data is automatically deleted again at our partners. The partners do not gain new addresses as a result of this. We think this is a great benefit for you as you get only those advertising which suits your needs.

Hays group companies & Hays advertising partners 

When we mention Hays group companies in Germany, Austria, Denmark and Switzerland in the context of our advertising consent wording, we mean the following legal entities:

• Hays AG, based in Germany
• Hays Professional Solutions GmbH, based in Germany
• Hays Talent Solutions GmbH, based in Germany
• Emposo GmbH, based in Germany
• Hays Holding GmbH, based in Germany
• Hays Beteiligungs GmbH & Co.KG, based in Germany
• Hays Vorrat 01 GmbH, based in Germany
• Hays (Schweiz) AG, based in Switzerland
• Hays Talent Solutions (Schweiz) GmbH, based in Switzerland
• Hays Österreich GmbH, based in Austria
• Hays Professional Solutions Österreich GmbH, based in Austria
• Hays Specialist Recruitment Denmark A/S, based in Denmark

When we talk about advertising partners in the context of our advertising consent wording, we mean the following partners:

• Facebook Inc, based in the USA, (https://www.facebook.com/about/privacy/update)
• LinkedIn Corporation based in the USA, (https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy)
• Google Ireland Limited, based in Ireland (https://policies.google.com/privacy)

Transfer outside of the EWR

Where we have asked you for your marketing consent regarding our advertising partners and where those parties are located outside of the European Economic Area, you consent (Art. 49 I a GDPR) to a transfer outside of the European Economic Area, and you are aware that there might be a lower level of data protection with these providers/countries than it is the case in the European Economic Area.

There might be in particular a risk that your data may be accessed through authorities for surveillance purposes, even without legal redress procedures. Exercising data protection rights, you know, and you are familiar with under the GDPR may be more difficult or even impossible.

Market research purposes

When you consented to the use of your personal data for market research purposes, this means that we will run surveys regarding satisfaction, NetPromoterScore, personnel topics, wishes, offers, socio-demographic characteristics, new platform testing, test groups, UX testing and brand panels.

Distinction between recruitment candidates and employees

Certain aspects of German law suggest a blurring of the line between recruitment candidates and employees. While we do not consider that this blurring was intended to apply in respect of candidates in the context of a recruitment business, should that not be the case, we would rely on the employment-specific provisions of the GDPR (and German law, i.e. the German Data Protection Act-new) to ensure that we can continue to process your data fairly and lawfully.

The employment-specific provisions permit the processing of personal data of employees for employment-related purposes where necessary for hiring decisions or, after hiring, for carrying out or terminating the employment contract or to exercise or satisfy rights and obligations of employees’ representation laid down by law or by collective agreements or other agreements between the employer and any staff council. For more information, please see section 26 of the German Data Protection Act-new. . 

ID check for pay-agent services (for suppliers and clients)

Purpose of data collection / kind of data we collect

As we provide you payment services according to § 10 Section 1 ZAG, we are obliged by the Money Laundering Act to establish the identity of each of our contractual partners or the person acting on their behalf and to document this. For this purpose, we use a web-based video identity verification process to make identification as convenient as possible for you. During this procedure, a Hays employee or an employee of our service provider, acting on our behalf and according to our instructions, will ask you to identify yourself by means of a camera. The interview will be recorded audio-visually and various images (screenshots) will be taken of the ID document you are using (the front and back, the respective security features), as well as of yourself. For this purpose, we ask you in at the outset of the interview, but before we start recording, for your consent under banking law in relation to the following:

(„We will take photos of you, as well as of the complete front and back of your ID card (including its security features) once in the course of this identity verification. Furthermore, the video call now conducted for the purpose of establishing your identity will be recorded visually and acoustically. We will store this data in accordance with our legal obligations. In this way, we will be able to provide proof that we have properly executed the videoIdent at any time upon request by the applicable regulatory authority.“)

Furthermore, the information contained on your identification document (for example, first name, last name, citizenship, etc.) is documented, stored and otherwise processed as part of the identity verification process.

Our processing of this information is necessary to ensure that we have identified you correctly and to document the identity verification process correctly.

Legal basis

Article 6 I c GDPR (compliance with a legal obligation), Article 6 I a GDPR (consent) and §§ 11, 8 GwG (Money Laundering Act)

Retention period

In accordance with the requirements of the Money Laundering Act, we retain the documents produced in their entirety for the duration of our business relationship with you or your organisation and beyond that for a period of 5 years.

Alternatives

Video identification is the fastest and most convenient method for you to identify yourself to us. We can and will also offer you alternative solutions for identification if you ask us about this and explicitly request an alternative.

ID check for all other Hays services (for candidates and suppliers)

Purpose of data collection / kind of data we collect

In today's virtual age, we unfortunately no longer meet many of our candidates, temporary workers and suppliers in person. As a result, we need to verify the identity of people (or in the case of organisations, people acting on their behalf) that we are seeking to do business with. This is done in for our own legitimate interests, namely to maintain internal compliance standards as well as to comply with our legal obligations (for example, we are obliged not to provide any or only limited services to "sanctioned persons").

For this purpose, we use a web-based video identity verification process to make identification as convenient as possible for you. During this process, a Hays employee or an employee of our service provider, acting on our behalf and according to our instructions, will ask you to identify yourself using a camera. The interview will be recorded audio-visually and various images (screenshots) will be taken of the ID document you are using (the front and back, the respective security features), as well as of yourself. For this purpose, we ask for your consent at the outset of the interview, but before we start recording in relation to the following:

(„We will take photos of you, as well as of the complete front and back of your ID card (including its security features) once in the course of this identity verification process. Furthermore, the video call now conducted for the purpose of establishing your identity will be recorded visually and acoustically. We will store this data in accordance with our legal obligations.“)

Furthermore, the information contained on your identification document (for example, first name, last name, citizenship, etc.) is documented, stored and otherwise processed as part of this identity verification process.  Afterwards, we check this information and if it turns out for us that the check was successful, we delete this data. In the event of discrepancies, we will clarify these with you and retain the data for this period. 

This information is necessary to ensure identification and to document the identity verification process correctly.

Legal Basis

Article 6 I f GDPR (legitimate interests condition)

Retention Period

We keep the data collected during the call for the period of the identity check and delete it afterwards. This period is usually a few days. After a successful identity verification check, we will keep a note on your file that your identity has been checked for the duration of our business relationship and for a period of 3 years beyond that.

Alternatives

Video identification is the fastest and most convenient method for you to identify yourself to us. We can and will also offer you alternative solutions for identification if you ask us about this and explicitly request an alternative.