Privacy Policy

Contact Information

If you would like more information about our privacy practices or have any questions in relation to this Privacy Policy please contact us using the details show below.

The Privacy Officer,
Worthington Legal Limited,
First Floor, 28 Stanley Street,
Central, Hong Kong

Email: [email protected]

About this Privacy Policy

This Privacy Policy sets out how WL collects, holds, uses and discloses your personal information. By visiting our website, requesting our services, applying for a job with us or otherwise providing us with your personal information, you consent to your personal information being collected, held, used and disclosed as set out in this Privacy Policy.

As a recruitment business we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process as we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees. In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements. To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

This Privacy Policy applies to all individuals (including our clients, the individuals whose personal information is collected from clients or other third parties, job applicants and prospective employees) who provide us with their personal information.

What personal data do we collect?

Personal data means any type of information (i) relating directly or indirectly to a specific living individual; (ii) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (iii) in a form in which access to or processing of the data is practicable.

Personal data may include:

• Name
• Date of birth
• HKID number
• Employer
• Photo page of passport and visa details
• Contact details
• Emergency contact details
• Work telephone number
• Work email address
• Work experience
• Qualifications
• Links to your professional profile available in the public domain eg LinkedIn or corporate website.
• Aptitude test results
• Opinions about your work performance (eg references)
• Incidents at the workplace
• Other personal data obtained or received by us in connection with your possible and actual work placements
• Personal data associated with managing queries and complaints

Depending on the nature of the role you are being considered for, and also depending upon the applicable jurisdiction, we may need to collect and process special categories of personal data about you which may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations.

In addition, as part of our commitment to equality of opportunity and to monitor compliance with our equal opportunity policy, we may ask you to complete an equality monitoring form. Where you are asked to complete an equality monitoring form, information is provided voluntarily and on an anonymous basis for statistical analysis. It is not stored with your other personal records.

WL may also collect your IP address, operating system and browser type for system administration and to analyse visitor trends and traffic on our websites – this information does not identify you individually and is not normally passed to third parties. We may also use your data to ensure that content from our site is presented in the most effective manner for you and for your device.

Where do we collect personal data about you from?

• Directly from you — this could be in person, over the telephone, by email, via social media or by filling in a candidate registration form on our website. By submitting information to us you declare that the information you have provided is complete and accurate at the time of submission and in order to facilitate future job applications you will provide any updates or amendments to your work history and job status.
• From an agent / third party acting on your behalf- for example this could be your own limited company or from another recruitment business or agency where you are applying to work for WL.
• From suppliers or clients- for example, we may collect your name and contact details as a business contact for your organisation. This could also include the results of competency based tests.
• From our website or apps- we may collect your IP address and other data about your engagement with our website or apps, for example, the pages you view.
• By reference or word of mouth — for example, you may be recommended by a friend, a former employer, a former colleague or even a present employer or we may get a reference from your previous employer or a named referee included on your application form or CV.
• Through publicly available sources with professional relevance. We use the following public sources:
  — Professional social media and networking sites (including LinkedIn)
  — Job Boards that you have registered your details on
  — Online curriculum vitae libraries
  — Corporate websites

Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programmes. These programmes are given parameters on the requirements of a role and search through publicly available sources, where there is a reasonable expectation that such information may be collected and processed by recruiters, to find candidates for particular job roles.

How do we use your personal data?

Your personal data will be used in connection with the services WL provide to you. This includes:

• carrying out our obligations arising from any contracts we intend to enter into or have entered into between you and us; • providing you with recruitment services – which may include career guidance and management to supporting businesses’ resourcing needs and strategies
• providing you with information about job vacancies and to assist you in finding a suitable position (either temporary or permanent) by matching your skills, experience and education with a potential employer;
• co-ordinating any test or assessment (including medical tests and assessments) that you might be required to undergo
• if you work for a client or a potential client looking to fill roles, contact you about candidates and to share your contact details with a candidate, at interview stage and subsequently;
• maintain our business relationship, where you are a user of our website, a client or candidate;
• if you are a potential employee, matching your skills, experience and education to, or contact you about, roles with
• record your IP address, operating system and browser type for system administration and to analyse visitor trends and traffic on our websites – this information does not identify you individually and is not normally passed to third parties. We may also use your data to ensure that content from our site is presented in the most effective manner for you and for your device;
• assist in our efforts to keep our site safe and secure;
• notify you about changes to our services or this Privacy Policy;
• carry out market research, marketing analysis and satisfaction surveys; • where you have provided your contact information for the possible use of our services, advise you of news and industry updates, events, services, promotions and competitions reports and other information that we feel may be of interest to you because it is relevant to your career or to your organisation. Where we do this you will be able to unsubscribe from such communications using the unsubscribe link
• with your express consent, use videos or audio recordings which include your image and/ or voice where you are presenting or part of a panel discussion or where you are part of a video interview for marketing or other business purposes; and
• complying with our legal obligations and rights, under contracts and at law, and to cooperate with authorities and investigations.

When do we disclose your personal information?

• Your personal data may be shared with certain third parties who will be subject to contractual obligations of confidentiality and compliance with relevant laws. These third parties may include:
• Our clients who have a position to fill, in order to determine with the client whether you are a good fit for the available position. We will not disclose your personal data to a client without your express written consent.
• The end client who you may be placed with through an intermediary such as an RPO
• Employees of WL
• Our suppliers, contractors and agents who may perform services for us, such as: professional advisors (for example, accountants or lawyers); IT software and service companies; research and mailing houses; event organisers and function co-ordinators; event co-hosts, payroll and other financial service providers; analytics and search engine providers that assist us in the improvement and optimisation of our site; credit reference agencies; insurance brokers; compliance partners and other sub-contractors for the purpose of assessing your suitability for a role (such as psychometric testing and reference/qualification checking)
• if required to do so by law, a court order or by a regulatory authority of competent jurisdiction or if we believe that such action is necessary to protect, defend or enforce the rights of WL.

Information from third parties

If at any time you provide personal data of a third party to us, you warrant and represent that:

• You have the consent of the third party to provide their personal information to WL.
• The intended use of personal data by WL and the promotion of WL recruitment services is consistent with and covered by the consent of the third party

Links to other websites

Our website or marketing email messages sometimes contains links to other websites. If you click on a third-party link, you will be directed to that site. None of these external websites are operated by ourselves and we cannot be held responsible for the content of other websites or the protection and privacy of any information you choose to provide to those websites. We therefore we strongly advise you to review the privacy policy of these websites.

International Data Transfers

Information that we collect may be stored, processed in and transferred between any of the countries we operate in order to enable us to use the information in accordance with this privacy policy. There may be circumstances where is it necessary to transfer your personal data to other countries, for example where the head office of a client is based oversees. This may include countries which do not have data protection laws equivalent to those in force in Hong Kong. However, we will take reasonable steps to ensure that the overseas recipient complies the applicable law and the WL Privacy Policy (for example by putting in place appropriate contractual arrangements with the recipient to safeguard your privacy). Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

Children’s Privacy

Our services do not address anyone under the age of 13. We do not knowingly collect personal data from children under the age of 13. In the case that we discover that a child under 13 has provided us with personal information we immediately delete this information. If you are a parent or guardian and you are aware that your child has provided us with personal information please contact us immediately so that we can action accordingly.

Security of your information

We will take all reasonable steps to secure your personal information that we collect and hold. Electronic information is protected by various security measures and access to information and databases are restricted to authorised personnel that need access to the information in order to perform their duties. While we have security measures in place designed to protect against the loss, misuse and alteration of personal data under our control we cannot guarantee that loss, misuse or alternation of personal data will not occur.

Please note that we cannot ensure that any information transferred over the Internet is fully secure and we are not responsible for any unauthorised disclosure or transfer. It is your responsibility to ensure you protect your personal information (for example, by protecting any usernames and passwords) and you should notify us as soon as possible if you become aware of a security breach.

Accuracy, access to and correction of your personal information

We will take all reasonable steps to ensure that the personal information that we hold is accurate, complete and up to date. Please contact us using the contact details below if your details have or are about to change, or if you wish to otherwise update or correct your personal information.

We will, on request, provide you with access to the personal information we hold about you unless otherwise required or permitted by law. We may charge a fee to cover the reasonable costs incurred in retrieving the information that you have requested.

If you would like to access your personal information, please make your request with the subject header "Personal Information Access Request" in writing addressed to our Privacy Officer using the contact details below and provide proof of your identity.

Updates to this Policy

The WL Privacy Policy will be reviewed and updated from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Any updates to our Privacy Policy will be posted on our website and we suggest that you regularly check our Privacy Policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of the Privacy Policy.

This Privacy Policy was last updated on: 12/10/2023