Privacy

Expertise is a leading professional service firm providing a broad range of Employment and Payroll and Accounting services. We are committed to protecting your privacy and the privacy of information provided. We do not share your personal information with any third parties, unless their involvement is critical to our service and express consent has been obtained.

We engage best practice security measures to protect information from unauthorized access.

Expertise is committed to processing data in accordance with its responsibilities under the applicable laws and regulations.

This statement explains Expertise’s information processing practices. It applies to any personal information you provide to Expertise and any personal information we collect from other sources.

This is a statement of our practices and of your rights regarding your personal information.

The Data Controller determines the purposes for which and the means by which personal data is processed. The Data Processor processes personal data only on behalf of the Data Controller.

This may also be explained in separate privacy notices made available when your personal information is first collected by Expertise (i.e. privacy notice may be provided when you or your employer engages Expertise to provide a service).

Some of the services which Expertise provides to its clients are provided as a Data Processor, which means that the Client remains primarily responsible for your information in their role as Data Controller. In circumstances where Expertise is not the data controller, we may re-direct a query about our use of your information to our client.

Expertise collects personal information in numerous different ways, depending on the service engaged.

For Recruitment Services:

1. When you register with or use our websites;
2. When you attend an employment search event;
3. When you reply to a recruitment advertisement;
4. When you engage with us over social media;
5. When you engage in an interview;
6. When we engage in dialogue with your employment or character references;
7. When engaging third parties offering independent verifications.

For Human Resources and Payroll Support Services:

1. When we perform services to our Clients.  Our services include corresponding with employment counterparties, managing on-boarding and off-boarding of employees and contractors, facilitation of human resources day-to-day operations, administration and business planning and the calculation of gross to net pay;
2. When our clients ask that we contact you directly in pursuit of the service objective.

For Immigration Services:

1. When we perform services to our Clients.  Our services include the processing of all work permit types, required residence applications, and other immigration initiatives that are personal and corporate in nature;
2. When engaging you to provide support for an immigration application;
3. When engaging third parties offering independent verifications.

Information you provide to us

When you engage Expertise for services, we ask that you provide accurate and necessary information that enables us to respond to your service request. When you provide personal information to us, we use it for the purposes for which it was provided as stated at the point of collection or as obvious from the context of collection.

In order to service your Recruitment request, we require the following information from you:

1. Your contact information [full name including all past and present aliases, address(es), phone number(s), fax number(s), email address(es)];
2. Your résumé/CV (and any updates thereof);
3. Reference contact details (name, business name, business address, business telephone number, your relationship with them and their position with the business). We assume that, before providing us with any contact details for your references, you have obtained their permission to do so;
4. A description of the types of positions that interest you;
5. Nationality.

In using our services, we may also ask you to provide us with the following additional information:

1. Educational records;
2. Reference letters; and
3. Results of specialized testing or professional designation testing.

Interview notes will also form part of the information we have on our file about you.

Information we collect from clients or third parties

For Recruitment services, we may collect the following:

1. Verification of education and professional qualification;
2. Verification of employment history;
3. Criminal and credit record check, if required by the position;
4. Information obtained through reference and background checks.

For Human Resources and Immigration services, we may collect the following:

1. Employer information, including payroll tax identification number, social insurance identification number, benefits statements and records, deduction policies and address;
2. Recruitment information, including full name, personal telephone numbers, personal email and residential/mailing address, resume and proof of qualifications (education details, work history), date of birth, pre-employment screenings and background checks;
3. Immigration applicant information, including full name, personal telephone numbers, email and residential/mailing address, photo identification, personal financial details, health standing, date of birth, résumé and proof of qualifications (education details, work history), nationality, character references, police reports, marriage certificates, dependents identification;
4. Employee information, including full name, work and personal telephone numbers, email and residential/mailing address, emergency contact details, self-selected racial category for Department of Statistics, contracts of employment, compensation / benefits / deductions information, social insurance identification number, attendance records, performance and training details, bank account information, employee relations records.

For Payroll services, we may collect the following:

1. Employer information, including payroll tax identification number, social insurance identification number, benefits statements and records, deduction policies, address and company bank account information where client requires direct debit;
2. Personal and/or professional contact information, including email address and telephone number;
3. Employee information, including first and last name, email address, compensation / benefits / deductions information, social insurance identification number, attendance records (if used in calculation of pay), date of birth and bank account information;
4. Geographic location

Information we collect over Expertise websites

We may ask you for some or all the following types of information when you make a service inquiry or register as an active job seeker.

This includes, but is not limited to:

1. Contact information such as name, e-mail address, postal address, phone number and mobile number;
2. Immigration status;
3. Number of dependents;
4. Work disciplines and industries of interest;
5. Résumé;
6. Username and password

The following is a summary of the purposes for which we use personal information.

Performing services for our clients

We process personal information which our clients provide to us in order to perform our professional services. This may impact you, for example, where you are the employee of our client. The precise purposes for which your personal information is processed will be determined by the scope of our client engagement. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to Expertise.

Expertise uses personal information for different purposes depending on the service engaged.

For Recruitment Services, we will use your personal information to assess your suitability for an employment opportunity based on:

1. Your qualifications,
2. Your work experience;
3. Your assessment results;
4. Work requirements, desires and other factors

For Human Resources and Immigration Services, we use your personal information in order to:

1. Process all work permit types, required residence applications, and other immigration initiatives that are personal and corporate in nature;
2. Correspond and liaise with employment counterparties (e.g. benefit providers and administrators, government agencies and legal advisors);
3. Carry out tasks relating to on-boarding and off-boarding of employees and managing temporary and contractor staff;
4. Facilitate human resources day-to-day operations, administration and business planning.

For Payroll Services, we use your personal information in order to:

1. Produce net pay and detailed payroll variance reports;
2. Produce secure electronic employee pay advices;
3. Facilitate direct deposit processing of payroll on pay days; and
4. Produce benefits reconciliation and facilitate settlement.

Administering our client engagements

We process personal information about our clients and the individual representatives of our clients in order to:

1. Carry out client screening prior to commencing a new relationship;
2. Carry out client communication, service, billing and administration;
3. Deal with client service delivery matters.

Contacting and marketing our clients and prospective clients

We process personal information about our clients and the individual representatives of our clients in order to:

1. Contact our clients in relation to current, future and proposed engagements;
2. Send our clients newsletters, promotional material and other marketing communications;
3. Invite our clients to events.

Legal basis

The processing of your personal information is supported by a lawful basis.

For Recruitment services:

1. If you are a job seeker, we will use your consent as the basis for processing your personal information;
2. If you are a client that requires our services to fill an open position, we will use legitimate commercial interest delivery of our services in terms of a contract you may not be party to, as the basis for processing your personal information.

For Human Resources, Immigration and Payroll services, we will use a contract (we help an employer to fulfill an obligation to you under an employment contract in relation to the delivery of employee benefits) and legitimate commercial interest (delivery of our services in terms of a contract you may not be party to) as the basis for processing your personal information.

Before collecting and/or using any special categories of data, or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be your explicit consent.

While our services generally do not extend to minors, we do facilitate networking and career programs and events which are open to local schools and school-aged students. In all instances, we work with student custodians and guardians where personal information is required for program registration and related initiatives to seek consent on behalf of minors.

Your personal data is only to be retained for the period of time required to fulfill the purpose for which it was collected (taking into account our statutory and contractual obligations to retain information), unless a longer retention period is permitted by law, in accordance with the Expertise Record Retention Policy.

Within Expertise

We may share your personal information with other Expertise group entities to serve you.

We do not share your personal information with third parties except in the circumstances outlined below.

Authorized Service Providers

We may disclose your information to service providers we have engaged (as data processors) to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.

These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’

Examples include:

1. IT service providers who manage our IT platform and telecommunications networks;
2. Clearing bank where your personal information is shared in order to facilitate online direct transfer of net pay;
3. Independent verification providers (i.e. credit check, police checks, background checks etc.).

These third parties appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.

Legal Requirements

Expertise may disclose personal information in the following instances:

1. If we are required to do so by law, regulation, or to respond to a subpoena, search warrant, or other legal request;
2. In response to law enforcement authority or other government official requests;
3. When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss;
4. In connection with an investigation of suspected or actual illegal activity.

Expertise operates in multiple jurisdictions and may transfer personal information across geographical borders to group entities or authorized service providers in other countries working on our behalf.

We use legal mechanisms to ensure your rights and protections follow your personal information:

1. We ensure transfers within Expertise are covered by agreements, which contractually place an obligation to ensure that personal information receives an adequate and consistent level of protection wherever it resides within Expertise;
2. Where we transfer your personal information outside Expertise or to third parties, we obtain contractual commitments from them to protect your personal information;
3. Where we receive requests for information from law enforcement, regulators or government agencies, we work to validate such requests before any personal information is disclosed.

Countries where we transfer personal information to include, but are not limited to, Bermuda, the United States of America, Canada, Cayman Islands and the Philippines.

Expertise has implemented a range of internal controls to protect your personal information. These internal controls are supported by policies approved, implemented and monitored by Senior Management.

We have implemented strong physical and logical access controls to prevent unauthorized access to your personal information. The computers and server equipment on which your personal information is stored are kept in a secure environment.

When we collect sensitive information, this information is encrypted and transmitted to us in a secure way using our encrypted portal or encrypted email. Requests for sensitive information by your employer are also directed through the encrypted portal or encrypted email.

Any handwritten interview notes are converted to soft-copy and stored in our secure Applicant Management System (“AMS”). Once added to AMS, all hard-copy material is destroyed.

We take reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.

Newsletters

If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.

E-mail

Contact us by e-mail as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes. If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.

Right to Access, Rectification, Restriction and Objection

Upon request, you shall be informed of the existence, use and disclosure of your personal data, and shall be given access to it. You may verify the accuracy and completeness of your personal data, and may request that it be amended, if appropriate. Should you believe that your information is being used for purposes other than in the carrying out of recruitment services, you have the right to request the restriction of such processing.

Contact us at the email address disclosed at the end of this Privacy Notice.

Summary information is available on request and we will attempt to respond to the request within 30 days of receipt. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees and may take longer to respond to.
 

Right to Withdraw Consent

Your knowledge and consent are required for the collection, use or disclosure of your personal data, except where inappropriate or permitted by law. Depending on the sensitivity of the information, this consent can be implied or expressed; however, wherever commercially feasible Expertise shall attempt to obtain express consent. Consent to our use of personal data can be withdrawn at any time by contacting the Data Privacy Officer in writing and following the directions at the end of this Privacy Notice.

Right to be Forgotten

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

Right to Lodge a Complaint

We hope that we can resolve any query or concern that you may have raised about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint.

The supervisory authority in Bermuda is the Privacy Commissioner who may be contacted at privcom@privacy.bm

The supervisory authority in Cayman Islands is the Office of the Ombudsman who may be contacted at info@ombudsman.ky

International Transfers

As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

Our policy notice will be posted on our website at www.expertisegroup.com. We will notify you of changes by posting the revised policy on the aforementioned webpages. Any policy revisions are effective immediately upon posting on the webpage.

We have the right to make changes to this policy at any time and advise that you regularly review this policy. If you object to any changes, please direct your comments your local privacy authority (refer “Right to Lodge a Complaint” section).

Should you have any questions or concerns about this policy or any concerns over misuse of personal data, please contact us:

Email: privacy@expertisegroup.com

Data Privacy Officer: Jason Wakeford