This Privacy Notice (“Notice”) describes how Protiviti Hong Kong Company Limited (“we”, “us”, “our” or “Protiviti”) may use, process, store and disclose Personal Information that we may collect about individuals, including if you register with us through this website, third party social networks and from other sources such as when you register for our online webinars. The types of data we collect are described in the section below ‘Your Personal Information and how we collect it’.
We act as a controller and we are responsible for the Personal Information we process. This Notice informs you how we protect your Personal Information and informs you about your privacy rights.
It is important that you read this Notice together with any other Privacy Notice we may provide and on specific occasions when we are collecting or processing your Personal Information so that you are fully aware of how and why we are using your Personal Information. This Privacy Notice supplements other Notices you may receive from us and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
If you have any questions about how we use your Personal Information, contact us at: [email protected].
Your Personal Information and how we collect it
Use of or registering with this Website
When you use or register with this Site, such as searching for information or applying for a job, we may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on our Site, we may also ask for and/or collect:
- your job search criteria, salary expectations and preferences;
- job title, company name, company location, industry sector, employment history, employment experience, educational history, skills, and salary;
- information about your professional interests through white papers or newsletters you request, as well as professional interests that you describe to us;
- other background information together with any login ID and password created by you;
- information you provide including in emails, letters or during telephone calls
- profile data including your interests, preferences, feedback and customer survey responses;
- usage data including information about how you use our website and services;
- marketing and communications data including your marketing and communication preferences.
Providing us with some of the Personal Information described above is necessary for performance of the services and functionalities offered by the Site, and we will notify you of the categories of data which must be provided to us. If you do not provide us with mandatory Personal Information, we may not be able to process your inquiry or other requests.
In relation to a job applicant, the Personal Information and information set out above provides us with an explanation of a job applicant’s past work experience, including details of any gaps or periods of unemployment and academic background, and may be used to obtain references. We may ask you to provide original, documentation in paper format, including proof of identity, evidence of immigration status and qualifications and we may verify some or all of the information you provide in relation to your application for a job. We may ask you to consent to a background check and or a credit reference check, where this is a requirement for the job. We may use a third party to perform background screening and verification services and we will inform you at the time.
If you provide us with information about 3rd parties, we will assume that the 3rd party in question has given you permission to do so and to Protiviti collecting, processing and transferring their Personal Information to the same extent as yours.
Our Clients and Suppliers
If you are a Client or supplier of goods and services we will collect and process information about individuals in your organisation to enable us to communicate with them and to provide our services or receive goods and services. We may also find the details of corporate contacts published on other websites and social media. We may enter the individual’s name and business email address into our database as a designated corporate point of contact for that client or supplier together with the individual’s other business contact data. Usually, the only Personal Information we process is the individual’s name for the purposes of contacting that client or supplier in relation to our services or as a recipient of the client or suppliers goods and services. The source of a corporate point of contact may be the individual themselves, or their name and business details may be provided to us by a member of their HR or Procurement department or another manager within the organisation. We may send business to business email marketing to corporate points of contact. An individual corporate point of contact can ask us at any time to stop sending business marketing emails to their business email address by visiting our Preference Center or by contacting: [email protected].
How we use your Personal Information
We use, process, store and disclose your Personal Information and other data we collect for the purposes of performing the services requested and functionalities offered by the site.
We use, process, store and disclose your Personal Information and other data we collect when you apply for a job at Protiviti (including emails, letters and during telephone calls and conversations) for the purposes described in this Policy and your potential employment relationship including: (a) processing and updating your Personal Information through the use of our HR online systems, learning platforms, performance management, payroll and pensions systems; (b) business planning, reporting and forecasting; (c) safety and security issues; (d) responding to your enquiries and complaints; and (e) to fulfil legal and statutory obligations.
We will also use, process, store and disclose your Personal Information for other legitimate business purposes such as producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our website and complying with other contractual, legal and regulatory obligations and duties.
Currently we do not use automated decision-making technologies to make final or conclusive decisions about you and a member of our staff will always be involved in the provision of working finding services.
Change of Purpose
We will only use, process, store and disclose your Personal Information for the purposes for which we collected it (e.g. the provision of work finding services if you are an Associate or to consider you for employment if you are a job applicant), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use, process, store and/or disclose your Personal Information for an unrelated purpose, we will notify you and, where required under applicable law, obtain your consent to process, store and/or disclose your Personal Information for that purpose.
We may use, process, store and/or disclose your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Transferring your Personal Information outside Hong Kong
Protiviti is part of an international group of companies operating globally. We may share some of your Personal Information with our group companies, our parent company, Protiviti Inc and our ultimate parent company, Robert Half Inc., based in the United States, and other group companies within or outside Hong Kong, who may use and process your Personal Information for similar purposes as described in this Privacy Notice. Such data protection laws may not provide an equivalent level of protection to those in Hong Kong. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it, including through written data processing terms and/or data transfer agreements.
Disclosing your Personal Information to 3rd Parties
To the extent necessary or appropriate, Protiviti may disclose your Personal Information to external 3rd Parties (who are not members of the Robert Half group of companies) in the following circumstances:
- to companies and individuals we employ to perform business functions and services on our behalf. Examples of service providers include those providing payroll services to enable us to pay our employees and temporary workers who work on client premises; background screening and verification services; data storage facilities including in Japan, Australia, the US and the Cloud; hosting our Web servers; analysing data and producing statistics and legal, accounting, audit and other professional services.
- to the extent necessary or appropriate to government or regulatory agencies including the Hong Kong Customs and Excise; the Hong Kong Inland Revenue Department; Hong Kong’s Office of the Privacy Commissioner for Personal Data and 3rd parties performing sanctions and terrorism checks;
- to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Protiviti or its group companies; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using our website or members of the public;
- to 3rd parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, we will let you know; and
- to IT consultants carrying out testing and development work on our IT systems, service providers who we may appoint as data processors and to other service providers who may be based in the United States and Australia.
Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to 3rd party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends, we will ensure your Personal Information is securely returned or destroyed.
Some of these 3rd parties are also controllers responsible for processing your Personal Information for their purposes, for example, the Hong Kong Inland Revenue Department is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers in connection with how they process your Personal Information.
Keeping your Personal Information Secure
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to do so.
We have put in place procedures to deal with any suspected Personal Information breaches and we will notify you and the applicable supervisory authority of a breach where we are legally required to do so.
How long we retain your Personal Information
Protiviti will retain your Personal Information for as long as necessary to fulfil the purposes that we collected it for, including for example making a job application to Protiviti or requesting Protiviti to provide work finding services. This means we will keep your Personal Information throughout the period of your relationship with us and whilst we are providing you with work finding services.
Your Legal Rights
You have the right to:
Make a Data Subject Access Request to access your Personal Information at any time. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Opt out of direct marketing You have the right to opt-out of direct marketing by asking us not to process your Personal Information for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by following the opt-out instructions contained in the relevant communications or contacting us in the email below.
Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise these rights or if you have any questions about our data handling practices, please contact our privacy officer at [email protected].
Additional information, Response Times and Fees
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that Personal Information is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help us locate your data and to speed up our response.
We try to respond to all legitimate requests within 40 days. It may take us longer than 40 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive or in other circumstances permitted under applicable law. Alternatively, we may refuse to comply with your request in certain circumstances and provide written notice and reasons for refusal within 40 days from receiving the request.
The Legal Basis for processing your Personal Information
We have set out a short description of main ways we will collect, store, process, share and disclose your Personal Information and the legal bases we rely on to do so.
We will only use your Personal information when the law allows us to. Most commonly, we will use your Personal information in the following circumstances:
- Where we have notified you that we will use your Personal Information, in accordance with the requirements of applicable law;
- When you consent;
- Where we are otherwise permitted to do so under applicable law.
We will seek your consent before sending direct marketing communications via email or text message.
With your consent, we may use your Personal Information to send you automated email messages or marketing materials regarding our services. If you are a job applicant we will provide you with relevant job opportunities. From time to time we may contact you for market research and quality surveys, including evaluating the effectiveness of our recruitment process. You may receive marketing communications from us if you provided us with your details when you submitted a website form, interacted with us online, entered a competition or registered with us at a job fair, promotional or networking event or attended a training course and you have given us consent to send you marketing. We may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.
We have established an email preference centre where you can view and make decisions about your email marketing preferences and opt out of receiving email marketing from us at any time.
You have the right to withdraw your consent to marketing at any time by:
- following the opt out links contained in our marketing email messages;
- following the opt out process described in our text marketing messages;
- Sending an email with “UNSUBSCRIBE ME” in the subject field to: [email protected].
Opting out of receiving marketing messages does not apply to:
- Personal Information that you have provided to us as a result of your request for work finding services;
- Personal Information that you have provided to us in connection with a job application;
- Personal Information that you have provided to us in connection with the performance of a contract between us;
- Job alerts sent to you through the website in response to your request to receive specific job details. You can select your preferences in the Job Search section and you can stop receiving these alerts at any time by clicking on the unsubscribe link within the job alert email; and
- Job alert emails which you will receive from our consultants which match your job search criteria confirmed with you during our Associate Registration process.
We will never sell or disclose your Personal Information to any 3rd parties to use for direct marketing.
Links to other websites
Our website may include links to 3rd party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these 3rd party websites and are not responsible for their privacy statements.
Feedback and Complaints
You have the right to make a complaint at any time to the Privacy Commissioner for Personal Data (“PCPD”) for data protection issues. We would ask you to provide us with the opportunity to discuss your concerns with you before you contact the PCPD, so please contact our Privacy Officer by email at [email protected] or by post at:
Protiviti Hong Kong Co. Limited
Attn: Privacy Officer
9th Floor, Nexxus Building
41 Connaught Road
Central, Hong Kong
Changes to this Privacy Notice
We may update this Privacy Notice from time to time. Where we are required to do so under applicable law, we will seek your consent to such changes. If we change material terms, we will provide notice of the revised Privacy Notice for 30 days on our home page at https://www.protiviti.com/HK-en.
This Privacy Notice was last updated: May, 2022.