Hydrogen Group plc ("We") are committed to protecting and respecting your privacy.
The General Data Protection Regulation (GDPR) is a new regulation which replaces the Data Protection Regulation. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
For the purpose of the Data Protection Act 1998 (the Act) and the GDPR, the data controller is Hydrogen Group plc of 30 – 40 Eastcheap, London, EC3M 1HD.
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site www.hydrogengroup.com (our site). This includes information provided at the time of registering to use our site (if applicable), subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.
- Information contained in your CV if you choose to upload one. On occasion this may include sensitive personal data such as details of criminal convictions or ethnic origin.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and others. In this case we will inform you, by sending you this privacy notice, of the fact we hold personal data about you, the source the personal data originates from, and for what purpose we intend to retain and process your personal data.
Where we store your personal data
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Legal basis for the processing
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Uses made of the information
Our legitimate interests in collecting and retaining your personal data is described below:
- To enable you to submit your CV for general applications, to apply for specific jobs, or to subscribe to our job alerts. Please see the CV section below for more details of how we may use or disclose the information in your CV.
- To provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To notify you about changes to our service.
We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you and we or they may contact you about these by post or telephone.
If you are a new user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please inform us through the preference centre we make available to you.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in NW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Please take note, if you attend one of our events, we often take photos and/or record the event to share with our networks who couldn’t attend in person, via social media or otherwise. You hereby consent to the sharing of any media taken at our events. If you attend one of our events and do not wish to appear in any post-event photos and/or filming, please contact us directly (email@example.com).
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Disclosure of your information
We may disclose your personal information to any member of our group both in the EEA and outside of the EEA, which means, where applicable, our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
- We will send your personal information, including sensitive personal information, to our clients in order for you to apply for jobs.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users / delegates will be one of the transferred assets.
- Where we have retained them to provide services, at the request of our client, such as reference, qualification and reference checking services, or the verification of any third party data provided by you.
Curriculum Vitae ("CV")
We give you the option of submitting your CV via our site or by providing your CV to one of our consultants. You can do this either to apply for a specific job or for general applications. Your CV will be stored in our database and will be accessible by our recruitment consultants in the UK, and other employees of Hydrogen Group of companies worldwide, including but not limited to Australia, Singapore and Hong Kong. Your CV may also be e-mailed directly to other Hydrogen Group plc global offices for review and entry onto their own in-house database to enable them to provide their services to you. In addition, our recruitment database, including the information relating to you, can be accessed by any of our recruitment consultants working in other offices of the Hydrogen Group plc, both inside and outside the European Economic Area, for such purposes as business development and to enable them to provide their recruitment services to you.
You are able to withdraw your permission for your data processed outside the UK upon completing your registration form with us or through our preference centres available to you.
You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).
By sending Hydrogen your CV, you are consenting to Hydrogen submitting your CV and profile to our Clients for recruitment purposes. This is only applicable where you are actively looking for work and are suitable for the applicable vacancies. You can manage this process by speaking to your relevant Hydrogen Consultant.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- prior to making an introduction we check that we have accurate information about you
- we keep in touch with you, so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re- enter your personal data on to our database, unless requested to do so. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current data retention period for all candidate personal data is:
- 2 years for all candidates where there is no recruitment activity.
- 4 years for candidates who have reached interview stage.
- 6 years for candidates placed, post placement date.
To subscribe to job alerts emails, you will be required to provide your e-mail address, which will be used for the purpose of keeping you informed, by e-mail, of the latest jobs in your nominated industry and/or will provide you with industry news. You can unsubscribe to job alerts should you decide to stop receiving such emails. Job alerts emails are sent by us or one of our group companies, some of which are outside the European Economic Area (in which case your details will be sent to or accessed by that group company to enable them to issue the relevant job e-mail alert to you).
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes in the registration form or preference centre we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Act and the GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. A subject access request should be submitted to email@example.com. No fee will apply once the GDPR comes into force.