Who we are and how do we process your personal data
Page Insights + is owned by Michael Page Recruitment Group Limited ("PI+" "we", “us”, or “our”) is part of PageGroup, and trades under the brands Michael Page, Page Personnel, Page Executive and Page Outsourcing.
We are committed to protecting the privacy of our clients and users of our website and the Page Insights+ platform.
We want to provide a safe and secure user experience. Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under all applicable data privacy and data protection regulations across all jurisdictions in which we operate and any other laws that may be applicable.
It also tells you about your privacy rights including your right to object to our processing. If you would like to contact us, please see the “How to contact us” section of this policy.
Personal data we collect
Users of our website or apps
We collect personal data such as your IP address and other data about your device which we need to provide our online content to you. We also collect data about your engagement with our website or apps such as the pages you view. If you contact us, we will also collect information about your enquiry. We might use cookies and similar technologies to collect a lot of this information and our cookie policy tells you more about this. We process this data to improve and personalise your experience when you use our website or apps
Clients
When a client enters into an agreement to obtain access to the Page Insights+ platform, we process personal data related to the individual’s signing on behalf of our clients (personal details for identification purposes such as full name, ID. number, and job title).
We also process personal data related to our client’s appointed beneficiaries (meaning our client’s employees to whom we will grant access to the to the Page Insights+ platform). We process this data to grant access to the Page Insights+ platform (for account-creation and identification purposes). The legal basis for this processing is the performance of our service contract with you.
We may also process any personal data you may provide to us when you contact us using the “Contact us” form found on the Page Insights+ platform. We process this data to aid our clients with any doubts or trouble they might have when using the Page Insights+ platform.
How we use your personal data
Users of our website or apps
We process the personal data related to our website/platform users for the following purposes:
• improve and personalise your experience when you use our website or apps.
Clients
We process your personal data for the following purposes:
• to communicate with you;
• to aid our clients with any doubts or trouble they might have when using the Page Insights+ platform;
• to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;
• to maintain our business relationship with you;
• to answer your enquiries when you contact us;
• to fulfil contractual obligations to you;
• to establish, exercise or defend legal claims;
Legal Grounds for processing your Personal Data
Users of our website or apps
The legal ground for the processing carried out to “improve and personalise your experience when you use our website or apps” is our legitimate interest in optimising the performance of our website and user experience, which in turn benefits all our website and app users.
Clients
Performance of a contract: The legal ground for most of the processing purposes detailed above is to adequately perform the contract we have entered into, by which you and your beneficiaries have been granted access to the Page Insights+ platform.
Legitimate interest: The purpose of “establishing, exercising and defending legal claims”, processing which is grounded in our legitimate interest in being able to properly address any claim raised by our clients or third parties.
Legal obligation: Lastly, we also store and process data to comply with legal obligations (for example, to comply with requests from the tax authorities). This processing will mostly take the form of storing personal data for a certain period of time and may be disclosed if lawfully required by an authority.
Consent: Though most unlikely, we might rely on consent for some specific ad-hod processing activities. You will always be informed of these activities prior to the commencing of the processing since we will only process under this legal basis with your express consent. To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. Please contact us, if you would like to withdraw your consent.
Automated Decision Making
We do not take decisions that may have an impact on you based solely on automated processing of your personal data; there is always human intervention before taking a decision.
Who we share your personal data with
In certain circumstances we will share your personal data with:
Other companies within our Group
PI+ is part of the PageGroup of companies which operates globally. Our key members of the business who run functions such as payroll and IT support are based all around the world. We may share with or give access to your personal data to other companies within PageGroup. Find a list of PageGroup entities and the countries where they are located.
We have in place an intra-group data transfer agreement containing the Standard Contractual Clauses approved by the UK Parliament for the transfer of personal data to ‘third countries’ (“SCCs”). The intra-group agreement also contains the UK’s international transfer agreement addendum to the SCCs. These SCCs act as an additional safeguard to permit cross-border transfers of personal data from within the EEA to third countries outside the UK and EEA, (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws). If you would like a copy of the SCCs, please contact us.
The purposes of sharing your personal data within PageGroup companies are: (i) providing essential services which are centralised in one single entity such as IT, commercial and sales support services, in this case these entities will access and process your personal data as data processors, following the instructions of your data controller, and (ii) the development of key accounts, which would require the cooperation of different companies across the group.
Third Parties
We may also share your personal data with third party service providers who perform services and functions on our behalf, such as:
• hosting personal data for us;
• providing professional advice to us;
• providing data analytics to us;
• carrying out testing and development work on our business technology systems;
• administering surveys or competitions on our behalf;
• assisting us to communicate with you; and
• providing research and mailing house or other direct marketing services.
We contractually require minimum standards of confidentiality and data protection from our third party service providers. If we need to send personal data outside the EEA, we will ensure that adequate safeguards are in place, such as the Model Clauses.
Other Disclosures
In addition, we may disclose your personal data:
• if we are legally required to do so;
• to law enforcement agencies, regulators or other government officials; and
• to the new business owners and their advisers in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business.
Keeping your personal data secure
We have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Only authorised personnel and third-party service providers are provided with access to personal data on a need-to-know basis, and these employees and service providers are contractually obliged to treat this information as confidential.
How long we hold your personal data for
We will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for, which may be an ongoing purpose.
We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.
Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.
Your rights in relation to personal data we hold about you
You have several rights under UK and EU data protection laws. These rights include the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data; to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of any relevant exemptions we are relying on when we respond to your request.
How to contact us
Exercising your rights
To exercise your rights, or to withdraw your consent to processing, or to unsubscribe from receiving marketing communications from us, you can:
• complete our GDPR contact form, or
• email us at [email protected], or
• write to us or our DPO at: [email protected]
DPO:
Bird & Bird DPO Services SRL
Avenue Louise 235 box 1, 1050, Brussels, Belgium
Page Group
Compliance Department
Plaza Europa 21 23, L'Hospitalet de Llobregat, 08908, Barcelona, Spain
Questions and Complaints
If you have any questions about our privacy policy, or about our processing of your personal data, or to make a complaint, you can email us or our DPO at the e-mail or postal addresses detailed above
If you have unresolved concerns, or believe that a personal data breach happened, you have the right to complain to your competent supervisory authority. A list of relevant authorities in the EEA can be accessed here.
Changes to our Privacy Policy
We may change this privacy policy at any time. If we do so, we will post updates on this site.