PRIVACY POLICY 

1. GENERAL

HireFirst, a trading division of SThree SAS, whose registered office is at 14e étage, Tour Europlaza, 20 Avenue André Prothin, Paris La Défense 4, 92400, Courbevoie, France and HireFirst Limited, whose registered office is located at First Floor, 75 King William Street, London, EC4N 7BE (together "HireFirst", "we", "us", "our") will be storing certain data that it collects on the HireFirst website, which is a resourcing solution (“HireFirst Platform”). You are being asked to read the terms of our data collection and processing practices in connection with the HireFirst Platform as set out below ( "Notice"). To proceed further, you must read this Notice in its entirety and check the "I HAVE READ THE PRIVACY NOTICE" box that follows.

2. CONTACT DETAILS

You may contact our data protection officer, with any questions relating to this Notice, and in order to exercise your rights (set out in section 7) as follows:

Mr. IVOR FRATER

DATA PROTECTION OFFICER

Email: dpo@sthree.com

3. WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?

Our main aim is to provide recruitment services to you and to facilitate a recruitment process. In order to do so, we collect the personal information mentioned in this section.

For users of the HireFirst Platform, which may include personnel of clients with a need for recruitment services and candidates interested in job postings, the personal data (which means any information about a living individual whose identity is apparent or can be reasonably ascertained from such information, including when in combination with our sources of information) we collect may include the following:

● Identity information - name, address, gender, personal contact details (including LinkedIn email address and telephone number), and, if provided by you, photographic images;

● Employment details - information you supply to us on your CV, job title, description of job role, work contact details (including work email address and phone number), details of technical skills and work history i.e. previous roles; and

● Background information - professional membership details and interests and preferences in a professional/personal sense which may be deduced from information provided by you.

If the provision of certain personal information is mandatory in order to provide your requests and for us to provide a service to you, we shall identify such fields in a clear manner [please specify how these fields will be identified]. Failure to provide such mandatory data may prevent us from providing all or part of the requested service.

Automated Decision Making

We use artificial intelligence and automation technologies to deliver a better, more efficient service to You, as follows:

· We adopt an automated process to filter the jobs that you are shown based on parameters that you have set, such as your preferred location to work;

· We then use "Natural Language Processing" to determine which jobs are ready for you to apply to. The natural language on your CV is matched with the natural language on job descriptions posted by our clients. Our technology understands words in the context that they are used, going far beyond keyword-based matching. This improves the relevance of the roles you are shown, while best positioning you for success in the job search.

You can always ask us not to automate this process and we will take care of your application without automation.

4. HOW WILL YOUR PERSONAL DATA BE USED?

Your personal data will be used by us in connection with the following purposes:

Service Provision and Internal Processing

Basis for Lawful Processing

 

• To provide a service to you (e.g. to facilitate the recruitment process, by matching candidates' details to job opportunities), and to provide information on such service, including to notify you about changes to such services.

HireFirst's use of your personal information is necessary to perform a contract with you.

 

It is also necessary to use your personal information in our legitimate interest as a commercial organisation.

• Where we have been given permission to do so, to allow details of candidates' skills and experience to be viewed by our clients whom we feel may be interested in engaging their services.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation. .

• To carry out our obligations arising from any contracts entered into between you and us.

HireFirst's use of your personal information is necessary to perform a contract with you.

• To confirm, update and improve our customer records to maintain an accurate and rich database.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation ..

• To respond to any queries or complaints that you raise.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation.

Management of Relationship and Direct Marketing

Basis for Lawful Processing

• To manage, analyse, understand and develop your relationship with us.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation.

• To keep you informed of any of our other/new services and identify services that may be of interest to you, where you have chosen to be made aware of this (see further section on Marketing below). This could include information about recently registered candidates / consultants, client workshops we are arranging, market updates, new software or training courses that may be of interest.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation and your consent where consent is required by local law

 

 

• To keep you updated about services provided by our third party business partners which are relevant to you.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation and your consent where consent is required by local law

 

• Where you have subscribed to our "job matching" service, to send details of the latest jobs via e-mail which are relevant based on sector and professional experience.

HireFirst's use of your personal information is necessary to perform a contract with you.

 

It is also necessary to use your personal information in our legitimate interest as a commercial organisation.

Analytics and Statistics

Basis for Lawful Processing

• To review the service we provide or have provided to you and carry out analytics and report on engagement.

HireFirst's use of your personal information is in our legitimate interest as a commercial organisation.

Legal Obligations

Basis for Lawful Processing

• If we are obliged to disclose information by reason of any law, regulation or court order and/or to protect our interests and legal rights.

HireFirst's use of your personal information is necessary for compliance with a legal obligation.

Other

Basis for Lawful Processing

• For any other purpose to which you agree. Where a purpose is not incompatible with the above, we may use your personal data for such compatible purpose, but we shall inform prior to further processing.

Your Consent.

5. MARKETING

From time to time, where you have requested to receive marketing information, we may send you information that we perceive may be of interest to you (including in relation to services of our partners, our subsidiaries and our affiliates). You may receive this information by SMS or email. If, at any time, you prefer not to receive further communications from us in any form (except in connection with information or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every email or SMS that is sent to you by us or by contacting us (see section 2 on contacting us).

6. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

From time to time, we may need to share personal data with third parties. These may include:

● our subsidiaries or affiliates - for the purpose of managing and administering our business and to provide you with information which might be of interest to you;

● entities who may or do acquire any rights in us - for the purpose of a business sale or re-organisation;

● our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts - for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;

● third party service providers - who need to know the information in order to provide us or you with service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, data storage, provide information technology and marketing services, customer services and for data analytics); and

● law enforcement and regulatory bodies - in order to comply with any legal obligation or court order.

With candidates' permission, we also share personal information with clients who we think may be interested in engaging such candidates’ services.

These parties may be located in the UK, other countries in the European Economic Area ("EEA") or in the USA. The data transferred includes the personal data described in section 3 of this Notice. Different privacy laws may apply in these countries. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any personal data held in that country or that the third party will act at all times in compliance with applicable privacy laws. Where personal data is transferred outside of the EEA, unless the recipient country is deemed to provide an adequate level of protection, we will put in place safeguards to ensure such adequacy. The safeguards we rely on in respect of international transfers include the following: data transfer agreements which incorporate the standard contractual clauses; or, where appropriate, the EU - U.S. Privacy Shield.

The HireFirst platform may contain links to other websites, which are outside our control and are not covered by this Notice. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours.

7. HOW WILL WE STORE YOUR PERSONAL DATA?

We have technical and organisational security measures in place and invest appropriate resources to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorised access, modification or disclosure. Wherever possible, we will ensure that our systems, and procure that our third party service providers’ systems, are appropriately secure for processing your personal data, and that the risks of your personal data being unlawfully used, amended, deleted, lost or stolen are minimised.

The personal data that you provide will be retained by us in accordance with applicable laws. However, we will take reasonable steps to destroy or de-identify personal data we hold, in accordance with our internal data retention policies and our legal obligations, if it is no longer needed for the purposes set out in section 4 above, including if you no longer have an active and on-going relationship with us. In general, this means that we will only hold your personal information for the relevant limitation period - i.e. the amount of time within which you can bring claims against us arising from our business relationship.

8. WHAT RIGHTS DO I HAVE IN RELATION TO MY PERSONAL DATA?

You have the right to:

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it. We rely on you to ensure that your personal information is complete, accurate and current. Please do inform us promptly of any changes to or inaccuracies to your personal information using the contact details below, or by updating your CV when logged in to the HireFirst Platform. To log in simply follow the links in your ‘job matching’ emails.

You can also request that we erase your personal information in limited circumstances where:

  • it is no longer needed for the purposes for which it was collected; or

· you have withdrawn your consent (where the data processing was based on consent); or

  • following a successful right to object (see right to object); or
  • it has been processed unlawfully; or
  • to comply with a legal obligation to which HireFirst is subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims;

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or

· it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

· you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

  • we have your consent; or
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

· the processing is based on your consent or on the performance of a contract with you; and

  • the processing is carried out by automated means.

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

You have the right to give directives relating to your digital legacy after your death.

If you are a candidate, you have the right to register on the relevant national phone solicitation opt-out list.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us (see section 2 of this Notice above), with subject heading "Exercise of Data Subject Right(s)". Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

9. COOKIES

Our Website uses cookies. Please refer to our Cookie Policy by clicking on the following link Cookie Policy.

10. CHANGES TO THIS NOTICE

 

Any changes we make to our Notice in future will be posted on the HireFirst website (https://www.hirefirst.com ). We encourage you to check this link whenever you use the HireFirst Platform for any updates or changes.