The Human Capital Group Group, including all Human Capital Group Group subsidiary companies together, (“Human Capital Group”) is a leading global recruitment consultancy and outsourcing company working on an annual basis with thousands of candidates and clients world-wide.
Our reputation as a recruiter is reliant on the trust of people we work with, and consequently the effective and professional use of the information you provide us is paramount.
Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and is in accordance with applicable data protection laws.
Important definitions in this policy
“You” are a candidate, potential candidate, consultant, client contact or contact at any other organisation involved in the introduction and/or supply of a candidate’s services, such as a contact at a recruitment process outsourcing company, personal service company or umbrella company.
References in this policy to:
- “hirer” and “client” mean any hiring organisation to which we offer and/or provide temporary and/or permanent recruitment services;
- “client contact” means a responsible owner at a client;
- “candidate” means a potential or actual candidate for a permanent or temporary role;
- “consultant” means a person whose services are supplied via Human Capital Group to work on temporary assignments with a hirer;
- “referee and/or emergency contact” means a person whose personal details a candidate provides for the purposes of providing a reference or acting as their emergency contact
It does not cover any use of your personal information by:
- an actual or potential employer or hirer;
- an umbrella company; or
What does Human Capital Group do?
The core of what we do is twofold.
Firstly, it is to provide services to help candidates develop their careers. We do this through assessing and matching people with potential job opportunities, as well as providing wider services to help them in their careers, such as invitations to networking events and opportunities to take part in research.
Secondly, we work with clients to provide recruitment, consultancy and outsourcing services to help them solve recruitment, talent, technology and other related challenges.
Where does Human Capital Group collect data from?
- via our website at www.hc-group.co.uk; or any other website operated by us (the “Site”); or
- as a result of you responding to an advertisement posted by us on a job board, online CV library or via social media; or
- as a result of us matching your CV, as uploaded by you onto a job board, online CV library or a social media site, to a vacancy we are seeking to fill for one of our clients; or
- as a result of personal recommendations; or
- from company websites; or
- from your business card; or
- in the course of us providing recruitment, resourcing, outsourcing or consultancy services to you (“Services”)
What information do we collect on Candidates?
Candidates: the personal information we collect about you where “you” are a candidate or placed consultant.
Human Capital Group aims to collect the minimum data it needs to perform its role. Typically, this is name, address, job title and contact details. In addition, if you are a candidate being considered for a role it may also include your CV / resume as well as other details about your skills and experience.
We may also collect other personally identifiable data, for instance we may be engaged in equal opportunity monitoring or need information to complete a contract for you or our client. This data can include age, identity card number, passport number, driver license number, address, email address, user ID and passwords, gender, date of birth, marital status, occupation, income range, bank account details, financial information, contact information such as telephone, mobile, nationality, personal website or social media links or other data which may be required by local regulations.
If you would like a more detailed description of the personal data we collect about you, please click here (https://hc-group.co.uk/appendix-1/).
Referees and emergency contacts: we collect basic contact details (such as name, title, address, email and telephone number) so that we can contact you for a reference or as an emergency contact for one of our candidates/or contractors.
What information do we collect on Client contacts?
Client contacts: the personal information we collect about you where “you” are a contact at one of our clients or at an MSP, umbrella company or personal service company involved in the supply of a person’s services to a hirer.
We need to collect information about you as an essential part of providing our Services.
We may collect personal information about you when:
we contact you with a view to providing Services to you; or
you email us expressing an interest in working with us;
you provide us with your business card or other information provided to us, given to our employees at sales and marketing events;
you post information or advertisements on job boards or social media websites;
we provide Services to you as an actual or a potential hirer of your services; or
we complete contractual documentation relevant to the Services,
we will usually collect the following information from or about you:
your postal address;
your phone and e-mail details;
details of your role, title and responsibilities within your organisation;
where “you” are a client:
any opinion or feedback you share with us regarding a candidate or consultant;
details of any queries you raise with us regarding the Services;
details of any recruitment and/or resourcing requirements or plans you share with us.
What is our lawful basis for processing your personal data?
We use the data we gather to perform a number of tasks, including:
placement of a candidate into a particular employment role as defined by our clients; or the provision of resourcing, outsourcing or consultancy
maintaining our records of our candidates, clients and contacts;
conducting marketing, profiling and business development activities as well as market research and statistical analysis regarding our products and/or services;
complying with any legal or regulatory requirements and to make the necessary disclosure under the requirements of any applicable law, regulation, direction, court order, guideline, circular or code which are applicable to us for the prevention of crime.
Client contacts: We use the information collected from clients to ensure that we provide business services to you. This will involve identifying candidates that will meet your requirements or providing other business services from our portfolio.
Suppliers: we use the data collected to ensure the business arrangements between us run smoothly.
Referees and emergency contacts: we use the data collected to contact you for a reference or to contact you as a candidate’s emergency contact in the event of an accident or other emergency.
Our lawful basis for processing your data: We consider that it is necessary for our legitimate interests as a recruitment business to process your personal data. At different stages in the recruitment processes we also have other lawful grounds for processing your data such as compliance with our legal obligations and where it is necessary for the performance of contracts related to the recruitment process.
A full statement of our legitimate interest may be found here (https://hc-group.co.uk/wp-content/uploads/2019/03/GDPR-Legal-Basis-of-processing-for-Human-Capital-Group-Ltd.pdf).
We think you will have an expectation that if you are looking for employment or have posted your CV or other professional information on a job board or professional networking site, that you are happy for us to collect and use your personal data to provide our recruitment services to you and to share that information with prospective employers.
During the recruitment process the client may want additional information (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, where appropriate and in accordance with local laws. We may also need to use your personal information for internal administrative purposes, such as contract administration, payroll and invoicing. We also have our own obligations under law and we may be required to share your data in connection with those legal requirements.
Where we are required by law to obtain your consent to the processing of your personal data we will obtain it.
Candidates and consultants – for a more detailed description of how we use your data please click here (https://hc-group.co.uk/appendix-2/).
Client contacts and other third parties involved in the supply of resourcing services (e.g. umbrella companies and personal service companies)
We collect, store and use your name and contact details for our legitimate interests, so that we can:
send you the details of candidates and consultants and contact you about our Services; and
maintain our business relationship with you.
This allows you to be contacted to receive and administer any Services which you or your organisation has requested. The exchange of personal data of our candidates and client contacts is an essential part of what we do as a recruitment business and, as such, it is in our legitimate interests to process your data for such purpose.
In the case of contacts at umbrella companies and personal service companies this allows you to be contacted to receive, on behalf of your employer, details of current and future assignments, related timesheet data and payment details.
We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
All users of the Site and our Services
We collect, store and use your personal information for the following purposes:
to make the Site available to you; and
to provide any Services that you request.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable in order to make them to operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
For more detail about these circumstances please click here (https://hc-group.co.uk/appendix-3/).
How do we share your personal information and who do we share it with?
Your personal data provided to us is processed by Human Capital Group Group Ltd. We will ensure that:
access to your personal data is restricted to staff who are required to process such data as part of their job;
only necessary information is released to the relevant employees;
we seek your consent before sharing your details with any prospective employer or user of your services.
Referees: unless you specify otherwise we may share your information with any of our group companies and client(s) in relation to whose vacancy your reference was given.
We will disclose information under the following circumstances:
Service and Site usage information: When we share anonymous information generated by our Services with our clients.
Third-party service providers: When we share information with third-party service companies for them to facilitate and support us in the provision of the Services.
IT support service providers;
providers of credit reference, vetting and screening services;
payment processors and software providers;
Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we may share your personal information with clients where we believe that you may be appropriate for a particular role or vacancy with that client.
Umbrella companies and personal service companies: When you inform us that you are supplying or intend to supply your services via Human Capital Group to a client through an umbrella company or personal service company.
Recruitment Process Outsourcing and Managed Service Providers: In certain cases, there may be an organisation such as a managed service provider acting as a gateway for the supply of Services made via Human Capital Group to the hirer. Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply.
Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.
We want to make sure that your data is stored and transferred in a way which is secure. We will only transfer data outside of the European economic area where the recipient is compliant with the data protection legislation and the means of transfer provides approved safeguards. These will include contractual clauses, the EU – US privacy shield framework, or where the country concerned has been found adequate by the European commission in respect to the levels of data protection.
Human Capital Group is a global company and to effectively provide the best service to our clients we may utilise a business processing outsourcing (BPO) service in India & the Philippines to help identify candidates for potential roles. This service helps us to respond more quickly to client services by identifying potential candidates and sending this information back to the responsible consultant. We have ensured that we have an appropriate business relationship to ensure privacy of your data.
We may send your information between Human Capital Group entities which may exist outside of Europe, to overseas clients or to clients within your country who may in turn transfer your data internationally.
The data may also be stored on cloud-based storage for parts of our overall business process.
Personal information, cookies and websites
Our website may offer you the opportunity to pass your personal information to us in relation to a particular role which is of interest to you. This information may be routed through one of our 3rd party suppliers before it is delivered electronically to us. All of our 3rd party suppliers have been vetted to ensure that they will meet our own privacy and security standards in the collection and processing of your personal information.
Technologies such as cookies, beacons, tags and scripts are used by us and our affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
How we safeguard your personal data
Human Capital Group is passionate about protecting your information. To this end we have put in place appropriate measures that are designed to prevent unauthorised access to and misuse of your personal data. These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by emailing DPO@HC-Group.co.ul.
Your information is held on servers hosted by us or our Internet Services Provider. 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.
We don’t keep data for any longer than is necessary. For most people where we have limited contact it will be for a maximum of four years from the date of last contact with us. Where we have engaged with you more extensively, for instance we have worked with you as client, or interviewed / placed you as a candidate, we may retain data longer.
We will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve disputes, or enforce our agreements.
For more information on our data retention policy please contact DPO@HC-Group.co.uk.
Your rights, complaints, questions and suggestions
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at DPO@HC-Group.co.uk at any time.
More details on your rights may be found here (https://hc-group.co.uk/appendix-5/).
Human Capital Group tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
If you wish to complain about this policy or any of the procedures set out in it please contact our Data Protection Officer via DPO@HC-Group.co.uk.
In the EEA, you may also make a complaint to our supervisory body for data protection matters (the Information Commissioner’s Office in the UK) or seek a remedy through local courts if you believe your rights have been breached.
Periodically we may send you information that we think you will find interesting or to ask for your expertise in completing a survey. We may also send you information to:
market our full range of services
send you details of networking and client events and information about the industry sectors we think may be of interest to you.
Subject to any applicable local laws and requirements we will not, as a matter of course, seek your consent when sending marketing materials relating to the above.
Where we have previously engaged with you (for example where you have submitted an application or CV to us) or where you have posted your details on a job board or Social Networking Site we will assume that you have given permission for us to contact you with details of roles which we believe will be of interest to you. You will have the right to withdraw such permission at any time.
Profiling, Anonymous data & Third-party sites
Human Capital Group does not utilise any form of automated profiling at this time. All of our recruitment activities involve human decision-making during the process. This may change in the future if we implement automated technologies or machine learning, but we will only do so where appropriate and in accordance with local laws and regulations. Any changes to this policy will be notified as set out below.
We collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
Third party sites: