Privacy Statement

Privacy Statement

May 2018

Why this privacy statement?

If you work for Hamilton Bright or one of its subsidiaries (collectively Hamilton Bright Group), or apply for a job with us, or visit our website out of interest, or make use of our app or respond to our social media posts, we need some of your personal data. Because we want to be transparent about the processing of your personal data by Hamilton Bright Group, we have published this privacy statement.

Hamilton Bright Group is committed to treating your personal data ethically and with care. This data is also processed and secured by us, on the basis of the General Data Protection Regulation (GDPR).

Below we have summarised the personal data we process, why we do so and how we handle your personal data. We also explain how you – as a client, employee, former employee, job applicant or visitor to our website – can exercise your rights to, for example, view your data or have it deleted.

Personal data that we process

Hamilton Bright Group processes your personal data because you make use of our services and/or because you have supplied this data yourself.

Below you will find a summary of the personal data that we process:

  • Forename and surname
  • Gender
  • Date of birth
  • Place of birth
  • Address details
  • Telephone number
  • E-mail address
  • Bank account number
  • IP address
  • Data about your activities on our website
  • Data about your surfing behaviour across various websites
  • Location details (SmartSpotter)

Sensitive and/or special personal details that we process

Hamilton Bright Group processes the following sensitive and/or special personal data about you:

  • Social security number (Burgerservicenummer, BSN)
  • Data about persons under the age of 16

Our website and/or service is not intended to collect data about website visitors under the age of 16, unless they have the permission of their parents or guardian. However, we cannot verify whether a visitor is over the age of 16. We therefore advise parents to be aware of their children’s online activities, to ensure that data about children is not collected without parental permission. If you believe that we have collected personal data about an underage person without such permission, please contact us via privacy@hamiltonbright.com and we will delete this information.

The purpose of processing personal data

Hamilton Bright Group processes your personal data for the following purposes:

Employees

Hamilton Bright Group collects and processes employees’ data for the purpose of maintaining a complete, accurate and effective personnel administration system, while taking account of the requirements of the Dutch tax authorities (Belastingdienst), accountants and legislation. In addition, Hamilton Bright Group uses employee data to implement elements of our personnel policy, such as the retention and motivation of staff, communicating information about company developments and the use of resources for the development of staff, including the Talent-X talent development system.

Job applicants

In respect of the collection of the personal data of job applicants, Hamilton Bright Group aims to compile and maintain an effective talent pool to fill vacancies that may arise now or in the future.

Legends

Hamilton Bright Group also processes the data of former employees, who are added to Hamilton Bright Legends if they have granted permission for this. The purpose of processing this data is to maintain a network of these former employees, to inform them about developments at Hamilton Bright Group and to communicate with them about activities organised for and with them, etc.

Website visitors

For Hamilton Bright Group, it is important that our website is very user friendly. To this end, we analyse surfing behaviour on the website. In this way, we can obtain a good picture of where we can optimise the website. We can see the surfing behaviour of our website visitors, but not who actually visits the website. Your data is always anonymous with us. In order to measure this surfing behavior, Hotjar is installed as a cookie on our website.

SmartSpotter

Via the SmartSpotter app, users’ location data is stored to detect fraud. The terms and conditions for the use of the app, and how this location data is handled, is specified in the SmartSpotter privacy statement.

How long we retain personal data

Hamilton Bright Group is obliged to retain certain personal data for five years after an employee leaves the company:

  • The income tax declaration.
  • A copy of the employee’s proof of identification.

There is no statutory retention period for the rest of the data in the personnel file. Hamilton Bright Group retains this data for two years after an employee leaves the company.

If this data concerns a job application, Hamilton Bright Group will request permission to retain this data if this is relevant for later opportunities. If this permission is granted, the retention period is one year, after which permission will be sought again if relevant. If the applicant does not grant permission, the retention period for the data is four weeks.

Once this period has expired, or if the data is no longer needed, Hamilton Bright Group will ensure that all papers and digital data are destroyed with care.

Sharing of personal data with third parties

Hamilton Bright Group does not sell your personal data to third parties, and will only provide this data to others if this is necessary for the implementation of our agreement with you, or to comply with a statutory requirement. We will conclude a data processing agreement with any companies that process your data on our behalf, to ensure that the same level of security and confidentiality is guaranteed. Hamilton Bright Group remains responsible for this processing.

How we protect personal data

Hamilton Bright Group takes the protection of your personal data seriously, and will undertake appropriate measures to prevent misuse, loss, unauthorised access, undesired publication and unauthorised changes. If you nevertheless believe that your data is not properly secured or if there is evidence of misuse, please contact privacy@hamiltonbright.com.

Viewing, altering and deleting data

You have the right to view your personal data, and to have it corrected or deleted. In addition, you have the right to withdraw any permission you may have granted for your data to be processed, or to object to the processing of your personal data by Hamilton Bright Group. You also have the right to have your data transferred. This means that you may ask us to send a copy of the personal data that we have on you in a computer file to you, or to an organisation specified by you.

You may send any request to view your personal data or have it corrected, changed or transferred, or a request to withdraw your permission or an objection to the processing of your personal data, to privacy@hamiltonbright.com.

To verify that the request to view your personal data came from you, we request that you send a copy of your proof of identification with your request. On this copy, obscure your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and social security number (burgerservicenummer, BSN). This is to protect your privacy. We will respond as soon as possible to your request, and within four weeks at the latest.

Hamilton Bright Group also wishes to point out that you may submit a complaint to the national watchdog, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). This can be done via the following link: https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

Cookies, or comparable technology, that we use

Hamilton Bright Group only uses technical and functional cookies, and analytical cookies that do not invade your privacy. A cookie is a small text file that is stored on your computer, tablet or smartphone the first time you visit the site. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website works properly and store your preferences, etc. They also allow us to optimise our website. You can opt out of cookies by setting up your internet browser so that it no longer stores them. You can also delete all data that has previously been stored via your browser settings.

When changes are made

Hamilton Bright Group reserves the right to change this privacy statement from time to time. We therefore advise you to regularly check this privacy statement for the most recent update.

If you have any questions about this privacy statement, please do not hesitate to contact us.

You can send any questions and/or remarks to: privacy@hamiltonbright.com.

Our privacy statement was amended on 21 May 2018