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Japan Privacy Policy

WILSONHCG – JAPAN PRIVACY POLICY

 

I. INTRODUCTION

 

This Privacy Policy applies to WilsonHCG Talent Japan KK (hereinafter referred to as “WilsonHCG” or “we” or “us” or “our”) and its subsidiaries respect the privacy of our users. This Privacy Policy applies to “you” our clients, business partners, candidates, anyone using our website (“users”), suppliers and any other third parties with whom we may work or to whom we supply our services, including recruitment.

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.

When you use this website, you trust us with information about you. Subsequently, you may provide us with Personal Data. Because your privacy is important to us, we recommend you read this privacy policy (“Privacy Policy”) so that you understand our approach towards the use of your Personal Data and contact us if you have any questions.

We have a separate Privacy Policy for our employees, which is provided to the employee and accessible to them on our intranet.

 

II. IMPORTANT INFORMATION ABOUT OUR GLOBAL WEBSITES

 

We are a global organization and we aim to comply with the legal requirements of each individual country. Therefore, we provide regionally specific privacy policies. Please read the privacy policy on our website applicable to you.

This Privacy Policy also describes how you can contact us about our privacy practices and to exercise your rights. 

Lastly, we use cookies on our website - please refer to “Section XIV. Cookie Policy” contained herein.

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:

United States

Wilson Human Capital Group, Inc. 

Wilson Worldwide, LLC dba WilsonCTS

Canada

Wilson Contingent Talent Solutions, Inc. WilsonHCG Canada Inc.

EMEA

WilsonHCG-EMEA Limited 

WilsonHCG Poland Sp.zo.o 

WilsonHCG Ireland Limited 

WilsonHCG France

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

1. Directly:

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.
2. Indirectly:

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 privacy@wilsonhcg.com

 

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 privacy@wilsonhcg.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

On our website, we may have links to websites of affiliated entities of WilsonHCG; however,, you may be referred to our website through a link from another unaffiliated, third party website. Therefore, we cannot be responsible for the privacy policies and practices of unaffiliated, third party websites. Access to any other Internet site linked to this website is at the user's own risk. We are not responsible for the accuracy or reliability of any data, opinions, advice or statements made on those sites, which includes but is not limited to any disclosures registrants make and that content is subject to their terms of use and any additional guidelines and privacy data provided in relation to that use on their website. Additionally, we do not intend to imply sponsorship, affiliation or endorsement with third-party sites.

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.

 

XII. COLLECTION OF NON-PERSONAL DATA

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. 

Third-party sellers, including Google, use cookies to serve ads based on someone’s past visits to our website. Of course, any data collected will be used in accordance with  our own privacy policy and Google’s privacy policies (you can find Google’s Privacy policy here:

 www.google.co.uk/intl/en/policies/privacy/.

 

XIV. COOKIE POLICY

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.

B. WHY DO WE USE COOKIES?

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website.

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?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third-party websites for information regarding their use of cookies. For further details on the third-party cookies that we use, see the third party cookies section below.

D. HOW DO I REJECT AND DELETE COOKIES?

We will not use cookies to collect personal identifiable information about you. However, should you wish to do so, you can choose to reject or block cookies set by us or the websites of any third party suppliers by changing your browser settings – see the Help function within your browser for further details.

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

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual.

Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

 

XV. DATA RETENTION

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 privacy@wilsonhcg.com.

 

Data Subject

How long Personal Data is kept

Potential Clients

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.

Clients

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.

Potential Suppliers

We will retain Personal Data for 6 months from the date of the last contact or as provided in the consent form if otherwise.

Suppliers

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:

privacy@wilsonhcg.com.

 

XVII. CHANGES TO THIS POLICY

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use your Personal Data we will post these changes on this page. Please check our Privacy Policy on a regular basis. 

 

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.

We value your opinions and feedback. If you have any questions, comments or concerns regarding our Privacy Policy, please send them to privacy@wilsonhcg.com or write to us at the following address:

WilsonHCG Talent Japan KK

and in English translation, WilsonHCG Talent Japan KK.

9F, Nakano Sunplaza,

No. 1-1, 4-chome, Nakano-ku, Tokyo