As a whole, we strive to protect the Personal Data that we may collect about our users, under our control and take certain precautions to help maintain the security and accuracy of the data. Under this policy, and in accordance with Japanese law, “Personal Data” is personal information constituting a Personal Data database. And, “Personal Data” is information relating to a living individual relating to the following items: those containing a name, date of birth, or other descriptions stated, recorded or otherwise expressed using voice, movement or other methods in a document, drawing or electromagnetic record (meaning a record kept in an electromagnetic form (meaning an electronic, magnetic or other forms that cannot be recognized through the human senses.
II. IMPORTANT INFORMATION ABOUT OUR GLOBAL WEBSITES
III. WHO ARE WE?
We provide recruitment processing outsourcing services, consulting, reporting, talent mapping, employment branding, analysis, fixed term contract services, executive search, perm search, and other recruitment related services.
Our company and our subsidiaries are:
Wilson Human Capital Group, Inc.
Wilson Worldwide, LLC dba WilsonCTS
Wilson Contingent Talent Solutions, Inc. WilsonHCG Canada Inc.
WilsonHCG Poland Sp.zo.o
WilsonHCG Ireland Limited
WilsonHCG Talent S.R.L.
WilsonHCG Hong Kong Limited
IV. PERSONAL DATA INFORMATION YOU PROVIDE TO US OR WE COLLECT
A. METHODS OF COLLECTING PERSONAL DATA
when you contact us, choose to provide data to us (for example you complete and submit a website form), use our services or provide products and services to us, engage with us on social media or, as a candidate, submit your CV/resume, attend an industry event, interview or take part in any psychological or medical assessment. Consent or other legal basis will always be obtained in order to process the data from any of these sources.
we may collect Personal Data from publicly available data relating to your job title, education and employment such as registration with professional bodies, qualifications and commercially available sources, for example from social media sites such as LinkedIn, public job boards, trade organizations, trade events, advertisements, B2B contact database, or other public sources.
B. TYPES OF PERSONAL DATA COLLECTED
1. Contact Details: your name, employer name, address, telephone number and email address.
2. Occupational Data: your job title, place of employment, experience, and/or skill set.
3. Candidate Recruitment Data for Job Opportunities: your role, skill set, education, experience, work history and any other data required in the recruitment process.
4. Submitted Job Application Data: your CV, resume, transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas.
5. Interview Related Data: obtained while conducting a phone interview, video interview, in-person interview, or interview through one of our third-party interview and recruitment service providers.
6. Reference Check Data: such as a verification of your educational and professional background, and other relevant data subject to WilsonHCG policies and applicable laws.
7. Billing & Payment Data: when we obtain your payment data we may collect bank account numbers, tax data, deposits and/or other pre-approved financial transactions.
8. Special Category Data: where appropriate and lawful, some of the Personal Data requested may be special category data, for example, which is Personal Data about an individual’s race; ethnic origin; politics; religion; trade union membership; health; sex life; sexual orientation; genetics and biometrics (where it is used for ID purposes). Should special category data be requested, expressed written consent shall be required and obtained prior to processing.
You can engage with us through social media websites, such as Facebook, LinkedIn, Twitter, Pinterest, Instagram, YouTube, Human Capital Connection blog, or through features at WilsonHCG.com that integrate with social media sites. If you use these websites, we will be able to access basic information from your social media profiles. Such information may include your name, email address, gender, pictures, geographic location or posts you write.
In addition to the information you provide, or accessed through social media websites, WilsonHCG may collect information from commercially available sources that it deems credible. Such information may include your name, address, email address, demographic data and occupation.
The above information may be stored in internal systems, such as client relationship management (CRM) and talent acquisition software (TAS) applications, on secure servers that are not accessible by third parties. These systems permit WilsonHCG employees to access and process such data solely for the purposes of customer fulfillment, business administration, business reporting, statistical analysis and marketing of WilsonHCG products and services.
We do not sell or rent our mailing lists to external organizations. We will not disclose your Personal Data to third parties, except with your consent or as required by law.
V. WHAT HAPPENS IF YOU DO NOT WANT TO GIVE US YOUR DATA?
If you do not supply us with Personal Data, then in some circumstances we may be unable to offer our complete services to you. For example, if you are a candidate and do not want to give us any of your contact details then we will be unable to contact you to discuss your requirements.
VI. HOW WE USE PERSONAL DATA
One of the purposes of our website is to inform you of who we are and what we do. We collect and use information to better provide you with product offerings and recruitment services.
Our collection and/or use of Personal Data may include:
A. Sharing within our internal teams and with our clients for recruitment purposes;
B. Communicating with you, including to let you know about important changes and or notifying you of content published by WilsonHCG which is likely to be relevant and useful to you;
C. Assessing your ability and suitability for the employment position/s you are interested in if you are a candidate;
D. Providing our services to you as and when you ask us to fulfil our contractual obligations to you (for example, supplying candidate data to prospective employers);
E. Fulfilling our contractual obligations to suppliers;
F. Asking third parties to provide services to us including professional advisors, IT (including cloud providers), marketing, recruiting and interviewing software or services, and outsourced services to help run our business properly and efficiently;
G. Marketing to you on industry specific content, provided that you consent to this;
H. Complying with regulations and legislation;
I. Resolving complaints and issues and establish and defend our legal rights or manage insurance claims in which you are involved;
J. Managing our business properly and efficiently; and
K. Providing you with information you request or indicate you may be interested in receiving.
To optimize our services, we may use your Personal Data for direct marketing. We take your privacy seriously and will only use your Personal Data when you are aware. If required by law, we will request your consent prior to using your Personal Data for direct marketing.
VII. YOUR PERSONAL DATA RIGHTS
You have the right to opt-out from the transfer of your Personal Data by a third party that received Personal Data after an initial “transfer.” You understand that the opt-out can only stop the “transfer” of Personal Data, and it does not impact other uses of their information. You can opt-out by emailing us at firstname.lastname@example.org.
VIII. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
When you provide Personal Data to an individual at WilsonHCG (for example a recruiter) you are providing that information to our whole organization. In addition, we share your Personal Data with various third parties depending upon your relationship to our company.
You can obtain more information on any providers or suppliers we share your Personal Data with by requesting a copy of any agents at email@example.com
Where necessary, your Personal Data may be shared with various third parties including:
A. Our third-party agents who provide services to us i.e. independent contractors Service providers who perform functions on our behalf i.e. payroll, benefits, insurance, and other administrative services;
B. Vendors, consultants, and other third party service providers to assist us in providing services on our behalf, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. data, interviewing, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training;
C. Third-party data storage providers who process data on our behalf i.e. email and storage provider, applicant tracking system;
D. Potential and active clients we provide recruitment services for, and to match the professional profile we have stored of our candidates in our database to any positions we have been asked to fulfill by any of our clients, and including any related administrative use such as invoicing;
E. Public authorities who make a lawful request, including to meet national security or law enforcement requirements.
IX. TRANSFERRING PERSONAL DATA OUTSIDE JAPAN
We do transfer some data outside Japan since your information is ultimately controlled by Wilson Human Capital Group, Inc., a company registered and based in the USA, but we have procedural and technical safeguards to protect the privacy of your data and to comply with the law.
X. SECURITY OF YOUR PERSONAL DATA
We have implemented technology and security policies, and other measures to protect the Personal Data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss.
WilsonHCG strives to protect the privacy of the Personal Data it processes, and inadvertent disclosure is unlikely. In the event of such an inadvertent disclosure, WilsonHCG will take all commercially reasonable steps to limit and remedy the disclosure. However, WilsonHCG cannot guarantee that unauthorized third parties will never be able to defeat those procedures or use Personal Data for improper purposes. Additionally, we also protect your information by requiring that all of our employees and others who have access to or are associated with the processing of your Personal Data, respect your confidentiality and sign company confidentiality agreements.
XI. EXTERNAL WEBSITE LINKS AND SOCIAL MEDIA
We recommend that you check the policy of each website you visit to better understand your rights and obligations, especially when you are submitting any type of content on those third-party websites. Please contact the owner or operator of such website if you have any questions/concerns.
We also collect information which does not identify you (Non-Personal Data). This includes the type of internet browser you use or the website from which you linked to our website.
We may also aggregate information which you have submitted to us (for example, your age and the town where you live) which is anonymous - you cannot be identified from this information. We share this aggregate information with third parties (for example to provide salary averages) to help us provide an effective service on our website.
XIII. THIS WEBSITE USES GOOGLE ADWORDS
Our website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. Find more information below.
Using Google AdWords means that we can advertise to previous visitors who have begun but not completed an action on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network.
A. WHAT IS A COOKIE?
Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any information stored on your computer or your files.
When a server uses a web browser to read cookies, they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.
Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in the comment forms.
Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer for longer.
C. HOW ARE THIRD PARTY COOKIES USED?
D. HOW DO I REJECT AND DELETE COOKIES?
Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies
Unless you specifically ask us not to, we will only keep your Personal Data for as long as it is:
A. Necessary for the purposes for which the personal data are processed;
B. To enable us to comply with our legal obligations, for example for tax purposes
Please refer to our data retention policy and timelines, which are dependent on the nature of our relationship with you. you can request the policy for your region at firstname.lastname@example.org.
How long Personal Data is kept
We will retain Personal Data for the length of time you have consented to, i.e. 2 years from the date of the last contact with us.
We will retain Personal Data for 7 years from the date that you ceased to be a client or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.
Potential Candidates who are not placed in employment using our services
We will retain Personal Data for 2 years from the date of the last consent or based upon consented duration if otherwise.
Candidates placed in employment using our services
We will retain Personal Data for 7 years from the date that you ceased to be an employee, or the legal requirements of your region as specified in the retention policy, whichever is longer.
We will retain Personal Data for 6 months from the date of the last contact or as provided in the consent form if otherwise.
We will retain Personal Data for 7 years from the date that you ceased to be a supplier or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.
XVI. CHILDREN’S POLICY
We do not collect information from children under 13. If we learn we have collected Personal Data of a child under 13, or equivalent minimum age of jurisdiction outside the above circumstances, we will take the proper steps to remove this information.
If you believe, at any time, that we have collected information from a child under 13, or you are a parent or guardian needs to access, correct, or delete their child’s Personal Data, please reach out to:
XVII. CHANGES TO THIS POLICY
XVIII. CONTACT US
Your information is ultimately controlled by Wilson Human Capital Group, Inc., a company registered in Delaware, USA with registered number 5370276 whose registered office is at: 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
WilsonHCG Talent Japan KK
and in English translation, WilsonHCG Talent Japan KK.
9F, Nakano Sunplaza,
No. 1-1, 4-chome, Nakano-ku, Tokyo