This Privacy Notice was last updated: January 20, 2023
This Privacy Notice describes how Robert Half Japan Ltd ("we", “us”, “our” or “Robert Half”) may use, store and disclose or handle in any way Personal Information that we may collect about individuals. We act as a business operator handling personal information (“controller”) and we are responsible for the Personal Information we process. This Notice informs you how we protect your Personal Information and informs you about your privacy rights.
We may modify this Privacy Notice from time to time. If we do, we will post the updated Privacy Notice on our website www.roberthalf.jp (the “website”).
This Privacy Notice should be read in conjunction with any privacy or collection statement we provide to you.
Your Personal Information and how we collect it
We will collect your Personal Information directly from you and from other sources including when you apply for a job via a job board, directly through our website, from Social Media sites such as LinkedIn, Facebook and Twitter or when you provide us with your details during a job fair, promotional, networking or training event.
When you ask us to provide you with work finding services, we will ask you to register as a Candidate. During our Candidate Registration process, we will collect your Personal Information directly from you, your CV, from employment referees and via online tests you may perform at our request.
We may disclose your Personal Information to our clients for relevant job vacancies. Our clients may request additional Personal Information about you in relation to their job vacancies and requirements.
Your Personal Information will be securely stored in our systems.
The categories of Personal Information we may collect include:
- your identity (your full name, previous names, evidence of change of name, gender, date of birth and marital status).
- evidence of your right to work in Australia which may include a photograph, nationality, place of birth, birth certificate, driving licence, etc (in accordance with Home Affairs requirements);
- contact details including your email, home address and phone numbers so that we can contact you by email and text message.
- bank account and Japan My Number Card number (so we can make payments to you and account for tax if you are working as a temporary worker supplied through Robert Half).
- pension details.
- your job search criteria, preferences and expectations.
- your qualifications, skills, experience and training.
- current and desired remuneration/payrate and other benefits.
- educational history.
- employment history.
- other information that you, your referees or our clients provide to us, including personal feedback and notes of our interactions with you and/or others in relation to your suitability for work with us or through us.
- aptitude and psychological assessment results.
- the results of background checks.
- other information contained in your CV or that you choose to provide to us.
- technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may also receive technical data about you if you visit other websites employing our cookies. Please see the ‘Cookie’ section below for further details.
- profile data including your username and password, your interests, preferences, feedback and customer survey responses.
- usage data including information about how you use our website and services.
- marketing and communications data including your marketing and communication preferences.
To provide you with work finding services our recruitment consultants will send you job alert emails matching your job search criteria and preferences. From time to time you may also receive job alerts which our consultants consider you may find interesting.
You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.
Applicants for Employed Roles
If you are applying for a role as our employee, we will collect Personal Information from you via your CV, referees, professional and educational organisations and other sources. We will process your Personal Information for the purposes of administering the application, managing the internal hiring process and assessing your suitability. We will store your Personal Information securely in our confidential online HR database. Your Personal Information cannot be viewed or accessed by anyone except for members of HR and Talent Acquisition in Japan, Australia and the US and other staff if they are connected to the hiring process, such as interviewing, assessing your suitability for the role you have applied for and communicating with you. We do not share our HR database with any group companies, and we will take steps to ensure that your Personal Information is adequately protected, secure and kept confidential. If we engage a third party to provide pre-employment screening services or testing, we will ensure that access is limited to the Personal Information that is compatible with those services and the service provider is contractually obliged to comply with applicable data privacy laws, confidentiality and provide adequate safeguards to keep your Personal Information secure until it is deleted or anonymised.
By applying for employment with us, you consent to us processing your Personal Information for these purposes. You have the right to withdraw your consent at any time. If you withdraw your consent, we will not be able to continue with your application.
If your employment application is unsuccessful, we will retain your Personal Information on our HR database for a reasonable period for the purposes of evidencing that we have conducted the recruitment process in a fair and transparent way and have not discriminated against applicants on prohibited grounds. At the end of the retention period, your Personal Information will be automatically deleted. Occasionally we may ask if you would like us to retain your CV data if we consider that you may be suitable for future roles. We will only do this with your consent.
Details about your health, unspent criminal convictions, court proceedings, or any pending proceedings relating to an offence committed or alleged to have been committed by you is only processed if it is relevant upon request of our clients and in accordance with the restrictions imposed by law. We may be obliged to disclose unspent convictions and criminal proceedings to our clients so that they can determine if these are relevant to your suitability for a role within their organisation, in such case we will disclose the information to the extent permissible under the applicable laws. If you disclose sensitive information to us, we will only collect this with your consent. This information will be retained for no longer than necessary before being deleted.
Our Clients and Suppliers
If you are a client or supplier or a potential client or supplier, of goods and services we will collect and process information about individuals in your organisation. We may enter the individual’s name and business email address into our database as a designated corporate point of contact for that organisation, together with the individual’s other business contact data. Usually, the only Personal Information we process about a corporate contact is the individual’s name for the purposes of contacting the organisation in relation to our services and authorising time sheets or the supplier as a recipient of the supplier’s goods and services. If the individual corporate point of contact is also a registered candidate, we may be processing additional Personal Information for work finding and other purposes as described in this Notice. The source of a corporate point of contact may be the individual themselves, or their name and business details may be provided to us by a member of their HR or Procurement department or another hiring manager or existing business contact or a candidate we have placed at the organisation. We may also obtain these details from websites, social media and other sources. We may send business to business email marketing to corporate points of contact. An individual corporate point of contact can ask us at any time to stop sending business marketing emails to their business email address by contacting: [email protected].
If you are a referee, we collect information that is reasonably necessary for us to determine a candidate’s suitability for work with us or through us. The main types of information we collect about referees are:
- your contact details including your address and telephone numbers; and
- details of your job title/description; and
- your confidential opinions about a candidate and their suitability for work with or through us.
Using this Website
When you use this website, we may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on our website, we may also capture your job search criteria and preferences, employment experience, salary, and other background information together with any login ID and password (if any) created by you. You can sign up to receive job alerts through the website by completing your job search criteria and preferences. You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.
If you do not provide such information, we may not be able to provide you with access to certain services and functionality of the website or with any other services you request.
How we use your Personal Information
We will only use your Personal Information for the purposes for which we collected it, and will not use or disclose any information about you without your consent, unless the use or disclosure is:
- for the purpose of disclosing information to our clients where necessary and appropriate in connection with the provision of a service to you;
- for the purpose of disclosing information to companies and individuals we employ to perform business functions and services on our behalf, on the basis that such companies and individuals must protect your Personal Information and may not disclose or use it for unrelated purposes. Such functions may include, for example, hosting our Web servers, analysing data, providing legal, accounting and marketing services;
- permitted under the the Act on the Protection of Personal Information;
- for health or public hygiene purposes and it is difficult to obtain consent;
- necessary to provide you with a product or service which you have requested;
- to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of Robert Half or its affiliated companies; (c) prevent a crime or protect national security (d) protect the personal safety of the users or the public; (e) to assist the investigation of an offence by a law enforcement authority; or (f) prevent a serious or imminent threat to an individual's life, health or safety or public health or safety; or
- as part of an automated solution to assess your suitability as a candidate for particular roles and for the purpose of considering your suitability for other, similar roles.
Please note that when the purpose of use is separately limited by laws and regulations, such as the use of individual numbers under the act on the use of numbers to identify a specific individual in administrative procedures (so-called My Number Act), we will not use it for any purpose other than the permissible purpose of use under the relevant laws and regulations.
We will also disclose your Personal Information to our Clients in relation to their job vacancies.
We may process your Personal Information for other legitimate business purposes such as producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our website and complying with other contractual, legal and regulatory obligations and duties.
If you provide us with information about third parties, we will assume that the third party in question has given you permission to do so and to Robert Half collecting, processing and transferring their Personal Information to the same extent as yours.
Our success is dependent on efficiently matching candidates to clients’ vacancies. In this context we use artificial intelligence (AI) provided by a third party based in the European Union as this assists our recruitment consultants perform the search and match of proposed candidates with client job vacancies more efficiently. The benefit of the AI search capability is that it supports our recruitment consultants to search more CVs and match personal data against clients’ job vacancies faster, ignoring irrelevant data. Our recruitment consultants are presented with a list of proposed candidates that are potentially suitable for a client’s vacancy, but it does not lead to automated decision-making. Our recruitment consultants decide which candidates to shortlist for a specific client’s job, based on their expertise, knowledge of the job market, insight into the client’s business and requirements for the role, candidate discussions and other relevant criteria. Clients’ (through their hiring personnel) decide which candidates to select for interview (if any). Our clients’ hiring personnel (not our AI tool) make the final decision on which candidate to select for their job (if any) and ultimately to proceed to hire/engage/employ the candidate.
If you object to the processing of your personal data by our AI tool our recruitment consultants will continue to provide work finding services using other methods to search for job opportunities for you. The personal data of candidates who are no longer available for work, not actively seeking a job, have recently commenced permanent employment or who object the processing of their personal data by AI, will be deleted by our AI service provider.
Disclosing your Personal Information to Third Parties
To the extent necessary or appropriate and without notifying you, Robert Half may disclose your Personal Information to external third parties (who are not members of the Robert Half group of companies) in the following circumstances:
- to third parties we employ to perform business functions and services on our behalf. Examples of service providers include providing payroll services to enable us to pay our employees and temporary workers who work on client premises; background screening and verification services; data storage facilities including in the US and the Cloud; hosting our Web servers; managing job posting applications via our third-party provider; analysing data and producing statistics and legal, accounting, audit and other professional services.
- If engaged through the Robert Half, processing of pay and other benefits related to your engagement may be processed by third parties in and outside Japan.
- to government agencies if required by applicable laws or regulations.
- to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Robert Half or its group companies and it is difficult to obtain your consents in advance; (c) prevent a crime, protect national security or for fraud detection or prevention and it is difficult to obtain your consents in advance; or (d) protect the personal safety of individuals using our website or members of the public and it is difficult to obtain your consents in advance.
- to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them; and
- to third-party IT consultants carrying out testing and development work on our IT systems, other service providers (including providers of relevant IT solutions) who we may appoint as data processors and who may be based outside of Japan where your data may be stored.
Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to third party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends, we will ensure your Personal Information is securely returned or destroyed or anonymised so that you can no longer be identified.
We may use your Personal Information to send you direct marketing communications or marketing materials regarding our products or services, including job vacancies. You may opt out of receiving such marketing communications by unsubscribing from our database.
We may also transfer your personal details to clients of the Company or third parties who provide services to the Company. These entities are located in Japan, Australia, United States, EEA and other countries.
The data protection laws outside Japan may not provide an equivalent level of protection to those in Japan and in these circumstances, we will take steps to ensure that your Personal Information is adequately protected, secure, kept confidential and that we have a lawful basis for the transfer.
Robert Half Japan Ltd, TOKYO TORCH Tokiwabashi Tower 24F, 2-6-4 Otemachi, Chiyoda-ku, Tokyo, 100-0004, Japan, Yewki Tomita will be responsible for the management of the jointly used Personal Information.
Robert Half will endeavour to take reasonable steps to protect Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. You should note that the internet is not a completely secure method of transmitting information and, as such, we are not responsible for the security of any information sent or received over the internet. Furthermore, Robert Half may disclose, and you consent to such disclosure of Personal Information to Robert Half servers and electronic systems located outside the country where you are located. This is due to Robert Half using overseas facilities to store, process or back up its information. However, this does not change our commitment to keep your information secure.
Access requests and correction
You are entitled to request access to any Personal Information that we hold about you and record of transfer if any, and you can do this by contacting us via email: [email protected]. You may request that we correct Personal Information that is inaccurate or out of date, erase and cease processing your Personal Information and cease transferring your Personal Information to third parties in accordance with the APPI, subject to limited exceptions set out in the APPI.
Subject to applicable laws, we may charge a reasonable fee to exercise any of these rights or refuse to comply with your request in certain circumstances. If you have any concerns or complaints about how we handle your personal information, or if you have any questions about this policy, our use of your Personal Information or our data protection measures implemented, and/or want to confirm the measures to exercise your privacy rights above, please contact us by emailing [email protected].
In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will provide our response within 30 days.
Revisions to the Policy
Robert Half Japan Ltd
TOKYO TORCH Tokiwabashi
Email: [email protected]