Hudson Privacy Policy

Hudson and its related companies (Hudson, we, our, us) is a talent solutions company with expertise in specialised permanent and contracting recruitment and talent management. We are a business built on trust, which is why we are committed to protecting the personal information of employees, clients and candidates. We encourage you to review the statements below explaining how we collect and use information you share with us.

The Hudson Privacy Policy ('the Policy') outlines how we collect, disclose, use, store or otherwise handle your personal information.

Content

CONSENT

By accessing our websites and/or submitting your personal information to us through any means including third party job boards and websites, you will be asked to consent to the use and disclosure of your personal information as set out in the Policy. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ’’Contacting Hudson’’.

PROCESSING YOUR PERSONAL INFORMATION

We are required to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

- -  We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  - Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or at your request prior to entering into a contract with you.
  - Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
  - Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  - Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

COLLECTING YOUR PERSONAL INFORMATION

The Policy relates to personal information collected by any means. It is our usual practice to collect this personal information directly from you. However, often your personal information is collected through the use of our website or in response to our online advertisements. Furthermore, there may be occasions when we receive personal information from a third party or a publicly available source.

The type of personal information we collect will depend on various factors such as the type of services you request or use and any applicable legal and regulatory obligations. This may include, but is not limited to, collection and use of the following kinds of information:

- - Contact information that allows us to communicate with you (e.g. e-mail, social media contact details, address, telephone number);
  - Identity information that allows us to identify you (e.g. name, date of birth, occupation, and government-issued identification);
  - Professional information that helps us to understand more about you including your employment history, qualifications, talents, skills and abilities (e.g. references, resumes, qualification documents and test results);
  - Financial information that allows Hudson to pay you should you be engaged as an employee or contractor (e.g. bank details, tax details);
  - Other individuals’ information we request, or that you provide, about an individual other than yourself (e.g. previous employers and referees); and
  - Immigration information that allows us to verify that you are legally permitted to work (e.g. evidence of citizenship, visa or work permit documents).

If you do not provide information, or the information provided is insufficient or inaccurate, this may limit our ability to provide services to you.

USE & DISCLOSURE OF PERSONAL INFORMATION

Hudson collects, uses and discloses your personal information in order to enable us to perform our business activities and operate our business functions. This includes;

- - Assisting you in finding or retaining work;
  - Assisting in your career performance or management;
  - Analysing human resource and labour markets;
  - Sending you marketing communications and information relating to our services which we think may be of interest to you;
  - Developing tests and assessments in order to place you in appropriate roles;
  - Paying you should you be engaged as an employee or contractor;
  - Helping in work rehabilitation or career transition;
  - Directly marketing recruitment services to you (you have a right to opt-out from receiving direct marketing emails);
  - Assisting clients identify suitable candidates and/or contractors;
  - Providing, maintaining and improving our products and services;
  - Responding to any work, health and safety obligation, claim, legislation or regulation; and
  - Developing new products and services.

Hudson may use and may disclose your personal information to third parties (located onshore or overseas) for the purposes it was collected, or for a related or ancillary purpose in connection with the performance of our business activities or operation of our business functions including but not limited to:

- - Hudson's related entities;
  - Prospective employers;
  - Clients who may wish to engage your services as a contractor or temporary employee;
  - Our vendors, consultant, suppliers, contracted service providers or partners, including (but not limited to) organisations that conduct competency or psychometric tests, payroll processing or other employment related services;
  - Your nominated referees;
  - Any government authority;
  - Any law enforcement body, including the police; and
  - Any educational or vocational organisations to the extent necessary to verify your qualifications.

Hudson is a multinational talent solutions company operating in different market and countries. From time to time, it is likely that we may need to transfer your data overseas in connection with our provision of services.

We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. While most of the personal information we collect about you is retained in country in which it was collected , there are circumstances where we provide personal information to overseas recipients. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

- - Cloud Computing Services
  - Communication & Collaboration Tools
  - Data Analytics Services
  - Data Storage Service Providers
  - Performance Monitoring Tools
  - User Account Registration & Authentication Services
  - Website Hosting Service Providers
  - Finance & Accounting Tools
  - Contracted Service Providers

We also may need to share your personal information in the following situations:

- - Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  -  We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  - Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

The country or countries to which your data may be transferred is not restricted, and may include: Australia, New Zealand, Singapore, Hong Kong, India, China, Pakistan, Philippines, countries in the EU or other countries from time to time. These countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

DATA QUALITY

In circumstances where your personal information has changed or you consider it is not accurate, up to date or complete you may contact the Privacy Officer who will endeavour to update and correct the information in accordance with applicable privacy law. We may also contact you from time to time to check the information is still correct.

DATA SECURITY AND STORAGE

Hudson takes reasonable steps to protect the personal information we hold from loss, unauthorised access, and misuse, including by means of physical and electronic security measures. Your personal information may be stored in hard copy documents, or electronically on our software or systems. If you suspect any misuse, loss or unauthorised access please contact the Privacy Officer immediately.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.

INFORMATION COLLECTED ON HUDSON'S WEBSITE

Users are advised that there are inherent risks in transmitting information across the internet. The Internet is an open system and we cannot guarantee that the personal information you submit will not be intercepted by others. Our websites may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. We cannot guarantee the content or privacy practices of any external websites and do not accept responsibility for those websites.

When you access our website, we gather information about users collectively. Such information includes the areas that users visit most frequently and the services users access the most. We will only use such data anonymously and in the aggregate. By doing so, we can optimise the services it provides to you.

USE OF COOKIES

We automatically collect certain information when you visit, use, or navigate the services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

FEEDBACK SUBMITTED TO HUDSON

Our websites have several areas on the site where you can submit feedback. We may use this feedback for marketing purposes, or to contact you for further feedback.

CONTACTING HUDSON

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.

Please contact our Privacy Officer if you have a request relating to any of the following:

- - if you would like to request access to, or correction of, your personal information held by Hudson;
  - if you would like to opt-out from receiving direct marketing e-mails; or
  - general queries relating to this Policy.

You may contact Hudson's Privacy Officer by email: privacy@hudson.com

PRIVACY COMPLAINTS

If you have a privacy related complaint, you may contact the Privacy Officer at the email address set out above. Your email should set out sufficient details of your complaint, including any alleged breach of applicable privacy law. Following receipt of your complaint, the Privacy Officer will consider your complaint and advise you of their determination and/or request further details.

The Policy has been adopted by the following companies within the Hudson group of companies: Hudson Global Resources (Aust) Pty Limited, Hudson Global Resources (NZ) Limited, Hudson Recruitment (Shanghai) Limited, Hudson Global Resources (Hong Kong) Limited and Hudson Global Resources (Singapore) Pte Limited and their related entities.

CHANGES TO THIS POLICY

We may change this Policy from time to time for any reason and will update the Policy accordingly. Any update to this Policy is effective on and from the date of publication.. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Australia only: If you are living or looking for work in New South Wales we are required by law to advise you of the following:

- - we must not charge you a fee for the purpose of finding employment;
  - we must not engage in misleading or deceptive conduct (such as advertising a position as being available when we know that no such position exists, or knowingly giving misleading information to you about the nature of a position); and
  - if you believe that we have acted inappropriately, you may contact the Office of Fair Trading for information on possible action that may be taken.

Last updated October 2022.