PRIVACY POLICY
Pursuant to Bermuda’s Personal Information Protection Act 2016
Privacy Notice
Hamilton Recruitment Services Limited (“HRSL”) is a company limited by shares, and was incorporated in Bermuda on 12th December 2024, Registration No. 202404299. We are an executive search agency that provides the following services:
• Executive Search & Recruitment
• Temporary Placements
HRSL has its registered office at Thistle House, 4 Burnaby Street, Hamilton HM11, Bermuda and its website may be found on www.hamilton-recruitment.com.
This privacy policy describes how we aim to collect and use personal information relating to candidates and employees during and after our working relationship in accordance with Bermuda’s Personal Information Protection Act (“PIPA”) 2016.
Who is collecting personal information and by which methods?
HRSL collects personal information through our application and recruitment process. This data is mainly collected either directly from the individual concerned; alternatively, the information may be obtained from an employment agency, a background check provider, our own website, external websites including LinkedIn, and/or other third-party sources.
What sort of personal information is collected?
The information we collect perform our services typically includes the following:
• Personal contact details such as name, addresses, telephone number and email address
• Recruitment information including full CV and work permit documentation
• Marital status, date of birth, nationality, information on dependants and Immigration status
• Salary, bonus, annual leave, pension, and other benefits information
• Start date and leaving date for prior roles, together with reasons if requested
• Passport or other documentation relating to proof of identity and residence
• Performance information as well as any disciplinary and grievance information
• Social Security/Social Insurance numbers together with bank account details, payroll records and tax status information
• Other pertinent information as may be required to perform our services properly
We may also need to collect, store and use information of a more sensitive nature including:
• Race or ethnicity, religious beliefs, sexual orientation and political opinions
• Information about your health, including any medical conditions, sickness records, including details of any authorised or unauthorised absences (other than holidays) from work including time on statutory parental leave and sick leave; and, where you leave a position of employment and the reason for leaving is related to your health, information about that condition that may be needed for pensions and permanent health insurance purposes
• Information about any criminal convictions and/or offences
If you fail to provide such personal information when requested, HRSL may not be able to perform its services properly and, depending on the nature of the particular failure, this may mean we might not be able to employ or engage your services or enter into a working relationship with you.
How will personal information be used?
Your personal information is used for a number of different reasons depending on what business relationship we have with you. We only seek to collect information that is necessary in connection with our relationship to you so that we can fulfil our role and responsibilities properly. Examples of how such information may be used is detailed below.
Executive Search & Recruitment:
• Matching your profile with appropriate permanent career opportunities
• Communicating with you to assess interest and coordinate the recruitment process
• Complying with professional, Immigration and legal requirements
Temporary Placements:
• Matching your profile with appropriate temporary career opportunities
• Communicating with you to assess interest and coordinate the secondment process
• Handling payroll and work permit responsibilities, as may be required
• Complying with professional, Immigration and legal requirements
With whom will the personal information be shared?
HRSL may share your personal information with potential employers or our clients, third-party service providers such as background check companies, Bermuda’s Immigration department, banks and government entities.
How can consent for collection and use of the personal information be provided?
We do not require your explicit consent when you provide your data voluntarily and in order for us to use your personal information in accordance with our Personal Information Protection Policy so as to carry out our legal obligations or exercise specific rights in the field of employment law.
In limited circumstances, we may approach you for your written consent to permit us to utilise sensitive personal information. If so, we will provide you with details of the information that we would like to use or share together with the reason we need it so that you may consider whether you consent.
How long will personal information be retained?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any staffing, legal, accounting, or reporting requirements. Once you are no longer a candidate, employee or contractor of HRSL, on request we will destroy your personal information.
What are your rights of access, restriction, correction and erasure?
It is important that the personal information we hold about you is complete, accurate and valid. Please keep us informed if your personal information changes.
Under certain circumstances, by law you have the right to request access to your personal information. This is known as an information subject access request. Making this request in writing enables you to receive a copy of the personal information we hold about you; this does not include access to information that you have not supplied to us.
You have the right to obtain from us restriction of processing depending on certain legal provisions.
If you wish to correct or erase this information, you may also make your request to us in writing. In such situations, HRSL may need to request specific information from you to help us confirm your identity and ensure your right to access such information. This is a security measure to ensure that personal information is not disclosed to any person who does not have the right to receive it.
International data transfers
When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws different to what you’re used to. By submitting your personal data, you agree to such transfer, storing or processing. We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
How do we keep data secure?
Security is a priority for us when it comes to your personal data and HRSL is committed to protecting your personal information.
Changes to our privacy policy
We reserve the right to makes changes to our privacy notice without prior notice.
Further information
If you have any questions about this privacy notice or how we handle your personal information, please contact our Privacy Officer, Thomas Burton, via our website’s CONTACT US page.
If you have any concerns about our use of your personal information, you can make a complaint to us via the contact details above.
Whilst we would always prefer to have the opportunity to resolve your complaint first, you can also complain to Bermuda’s Privacy Commissioner should you not be satisfied with how we have used your personal information.
The Privacy Commissioner
Maxwell Roberts Building
4th Floor, 1 Church Street
Hamilton HM11, Bermuda
Helpline number: +1 441 543 7748
Website: www.privacy.bm
Email: privcom@privacy.bm
*This version of our policy was uploaded in March 2025. It may since have been updated. Please contact us for the latest version