This privacy policy (together with our Terms of Engagement and any other documents referred in it) sets
out the basis for processing any personal data we, HR Jersey Limited (“HR Jersey”, “we”, “us”) collect
from you or that you provide to us. This policy meets the requirements of the European Union General
Data Protection Regulation (GDPR), and the GDPR equivalent legislation passed in Jersey and
Guernsey.
Please read the following carefully which sets out your rights as a data subject and to understand our
practices regarding your personal data. Depending on the purpose for which you are providing your
personal data, for the purpose of the Data Protection Act (the ‘Act’), the data controller (or entity
responsible for the data collected) will be us.
Data we may collect from you
We may collect and process the following data about you:
• If you contact us, we may keep a record of that correspondence. If you send us personal
information, which identifies you via email, we may keep your email and email address. We may
also collect information that is available from your browser;
• Contact details (including names, postal addresses, email addresses and telephone numbers);
• Information provided in the course of the provision of HR services (for example, information on
professional relationships and background, employment status and contractual information,
health data, remuneration information);
• Information acquired/provided through our website. This includes information provided using our
Contract Us form or requesting further services;
• Details of your visits to our website including, but not limited to, traffic data, location data,
weblogs and other communication data, and the resources that you access;
• Details of your access to our online resources or other materials;
• Providing CVs or other information about yourself for specific purposes;
• Information required for us to meet legal and regulatory requirements;
• Financial information, such as payment related information;
• Meetings attended and visits to our offices; and/or
• Any other information you may provide to us.
We may collect information about your computer, including where available your IP address, operating
system and browser type, for system administration. This is statistical data about our users’ browsing
actions and patterns, and does not identify any individual.
How we use your data
Your data will only be used for the purposes indicated when you submit the data or as detailed under
this privacy policy.
We use personal information held about you in the following ways:
• To enter into client relationships and provide HR services.
• To manage out client relationships ensuring business is conducted efficiently and with a view to
enhancing client service.
• To meet all legal, regulatory and ethical obligations applicable to us.
• To update and enhance our records.
• To compile information relating to your use of our services and make recommendations about
services and other areas that may interest you.
• To ensure the content from our website is presented in the most effective manner for you and
your computer.
• To carry out our obligations arising from any contracts entered into between you and us to
provide you with the information, products and services that you request from us.
• To provide you with information about our goods and services which may interest you. If you are
an existing customer, we will only contact you by electronic means (e-mail or SMS) with
information about goods and services similar to those, which were the subject of a previous sale
or negotiations of a sale to you. If you are a new customer, we will contact you by electronic
means only if you have consented to this. You can opt-in/out of such notifications by following
the instructions on the relevant forms or at any time after providing your information.
• We may analyse your data to create a profile of your interests and preferences so that we can
contact you in the most appropriate way and with the most relevant information.
In certain instances, personal data processed may include “Special Category Data” (which includes
information on a person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural
person, health data, data on a person’s sex life or sexual orientation or data relating to a person’s
criminal record or alleged criminal activity). In such instances, legal bases for processing that data may
include explicit consent (where the Special Category Data has been provided to us by the data subject
for any of the above-listed purposes) or the processing being necessary for compliance with a legal
obligation or the purposes of HR advice.
Sources and Recipients of data
The sources of data may include clients, intermediaries, data subjects directly, third parties connected
to the data subject (for example, their employer or another service provider who provides services to the
data subject) or open-source material.
The following is a list of potential recipients of data (in each case including respective employees,
directors and officers):
• Other members of HR Jersey Limited;
• Other providers of services where disclosure to that provider of services is considered
necessary to fulfil the purposes set out above;
• Any sub-contractors, agents or service providers of HR Jersey Limited;
• Courts or tribunals;
• Third parties with whom the we engage for the hosting of events or other marketing initiatives;
• Law enforcement agencies where considered necessary for us to fulfil legal obligations
applicable to it; and/or
• Regulators or other governmental or supervisory bodies with a legal right to the material or a
legitimate interest in any material.
Disclosure of your data
We will not transfer any of your data to any third parties without your permission or unless indicated in
this privacy policy or agreed by you in writing.
We may disclose your personal information to third parties without obtaining further consent from you
including:
• To our business partners, suppliers and subcontractors for the performance of any contract we
enter into with you.
• Where we outsource any of our business functions under which we collect or store your data, in
which case we will ensure that any such service provider adheres to at least the same
obligations of security with regard to your data as undertaken by us.
• Where 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 are under a duty to disclose or share your personal data in order to comply with any legal
obligation, or in order to enforce or apply agreements; or to protect our rights, property, or safety
of our employees, our customers, or others. This includes exchanging information with other
companies and organisations for the purposes of fraud protection and credit risk reduction.
We will never sell your data to third parties for the purposes of marketing.
Where we store your data
The data that we collect from you may be transferred to, and stored at, a destination outside the
European Economic Area (‘EEA’). By submitting your personal data to us, you agree to this transfer,
storing or processing. We will take all steps reasonably necessary to ensure that your data is treated
securely and in accordance with this privacy policy. Any payment transactions will be encrypted using
SSL technology, where possible.
Your rights
Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European
Union General Data Protection Regulation) have certain rights in respect of their personal data.
Any such data subject wishing to exercise any rights under applicable data protection laws (including
the right to withdraw any consent to processing previously given; the right of access to data; or to have
data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any
third party; or to object to any particular processing) should send the request in the first instance to
info@hrjersey.je.
In any case in which a data subject chooses not to provide any personal data or where any of the rights
set out above are exercised to limit the processing of personal data we may be unable to provide
relevant services, or there may be a restriction on the services that can be provided.
If you wish to change your mailing preferences or opt-out of specific marketing communications sent
from the HR Jersey Limited, you may notify us via our Contact us form. Alternatively you may contact us
on +44 (0)1534 629926. It may take up to 21 days for the changes to come into effect.
Our website 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.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised
in accordance with the Act. Any access request may be subject to a fee (as amended from time to time)
to meet our costs in providing you with details of the information we hold about you.
If you would like to request a copy of your personal data under the Act or have any other related
queries, please email info@hrjersey.je.
Retention
We only keep data for as long as necessary to fulfil the purposes (as set out above) for which we
collected it. It is our policy is to retain data in relation to a client matter for 10 years from the conclusion
of that matter. This is subject to certain exceptions or in instances where the personal data is relevant to
a dispute after closure of the matter or where the data cannot be deleted for legal, regulatory or
technical reasons.
Accuracy
We will take reasonable steps to create an accurate record of any personal data you have submitted.
However, we do not assume responsibility for confirming the on-going accuracy of your personal data.
You can update your personal data by emailing us at info@hrjersey.je or by calling us on +44 (0)1534
629926. Please note that it will take up to 21 days for the changes to come into effect.
Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be made available by request.
Contact
HR Jersey Limited is a registered data controller with the Data Protection Authority in Jersey. Any
complaint may be brought to the attention of the Authority.
Questions, comments and requests regarding this privacy policy are welcomed and should be
addressed to info@hrjersey.je.
May 2018