Latest update: 9 May 2023
General information
The LHH group of companies (LHH) is a part of Adecco Group AG, based in Zürich, Switzerland.
LHH is committed to protecting your privacy. This Privacy Notice tells you what to expect us to do with your personal data when you contact us or use one of our services, when you visit this website or when you access or use any applications or features made available by us (collectively, the “Website”).
California residents, please see below our California Privacy Notice at Collection, and California & Other U.S. State Privacy Rights sections.
LHH may supplement this Privacy Notice with other privacy notices if you register for specific services.
For example, if you are working with LHH Recruitment Solutions (including Badenoch&Clark, Spring or ADO trading as LHH Recruitment Solutions) seeking an interim staffing placement, you will also want to review the LHH Recruitment Solutions Candidate Privacy Notice.
If you are receiving LHH Career Transition services through your employer, you will want to review our CT Candidate Privacy Notice.
Our contact details as the Data Controller of your personal data
The LHH entity which provides you the LHH services is the Data Controller of your personal data. You can address any privacy related queries to your Data Controller by completing this form or via email to privacy@lhh.com.
What categories of personal data does LHH collect and use?
Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked in an individual (such as anonymous data).
We collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us:
Identity Data includes your first name, last name, and documents evidencing your identity if needed.
Contact Data includes your email address, telephone number and postal address.
Professional Data includes your job title, job level, your company name, details on your company and your company’s business needs, your location, your professional qualifications, educational and professional background, and salary where applicable, experience working with our brands, purpose of attendance (at an event), and other information that could be on your business card or that you choose to provide to us.
Marketing Communications Data includes your preferences on content type, frequency of communications and preferred language.
Social Media Data includes your profile data and other information you made public on or otherwise share with us from social media and/or job boards.
Profile Data includes information about you, provided by you on our electronic portals or platforms including your username and password, services or products ordered by you, your system preferences, your user-generated content (for example job searches, job applications), your feedback including your survey responses.
Usage Data includes information about how you use our Website, systems, products, and services.
Technical Data includes technical information collected when you access our electronic portal or platform, and includes your login data, access dates and times, browser type and version, device information, cookie data, 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 the Website.
Sensitive data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. When you visit or interact with our Website, you are not required to submit Sensitive Data. However, if you decide to provide us with Sensitive data, we will handle the information according to the practices identified in the applicable Privacy Notice. We reserve the right to delete the information from our databases in accordance with applicable law.
Why do we process your personal data and on what legal basis?
We normally collect personal data from you only where we need it to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.
If you are from a region that requires a legal basis for processing personal data (such as the EEA or the UK), our legal basis for collecting and using your personal data will vary depending on the personal data concerned and the specific context in which we collect it.
Please note that some information below may not apply to you depending on your relationship with us and/or the legislation of your home country.
Purposes of the processing | Type of personal data | Legal basis to process your personal data |
|---|---|---|
To provide you with our services and to attempt to establish or strengthen a business relationship with you. | a) Identity Data | - Performing a contract or taking steps prior to entering a contract in respect of the contract with or related to you |
To keep you informed about our services, via email, messaging, phone, social media or any other channel. This includes information such as events or newsletters that may be of interest to you. | a) Identity Data | To keep you informed about our services, via email, messaging, phone, social media or any other channel. This includes information such as events or newsletters that may be of interest to you. a) Identity Data b)Contact Data c) Marketing Communications Data d) Social Media Data if applicable - Consent where we are required under the law to obtain consent for marketing |
To respond to your request or questions or provide information when you contact us or make a request to us. | a) Identity Data | Fulfilment of our legitimate interests to respond to you |
- To allow you to participate in interactive features of the Website, when you choose to do so; | a) Identity Data | Fulfilment of our legitimate interests to administer our websites and provide you with relevant information about our products and services |
Where necessary, to comply with any legal obligation. | All types of personal data mentioned in section 3 as necessary. | Compliance with a legal or regulatory obligation |
To investigate or respond to incidents and complaints and/or to comply with investigations carried out by the police, government or regulators. | All types of personal data mentioned in section 3 as necessary. | - Compliance with a legal or regulatory obligation |
How do we get your personal data, and do you have to give them to us?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
register for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies and from the communications we receive from your browser.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Public information made available by you on social media and similar websites and apps;
Public information about you in directories, for example of professional memberships or qualifications.
You are not obliged to provide your personal data to us, but it would not be possible for us to work with you, or provide our services to you, if you do not provide us with a required minimum.
How long do we keep your personal data for?
We keep your personal data only as long as necessary to provide you with the LHH Service and for LHH's legitimate and essential business purposes, such as carrying out the LHH Service, complying with our legal obligations, and resolving disputes.
In some circumstances, we might anonymize your personal data so that it can no longer be associated with you, and use this indefinitely, without further notice.
What marketing communications do we send?
Communication with Individuals
We will only send marketing communications to you, as an individual, if you have consented to us doing so.
To receive marketing or promotional communications, you can opt-in by checking the relevant box located on the form on which we collect your data.
Communication with Businesses
We process your data within the scope of an existing business relationship with you or your company because:
We have a contract with you (or are considering entering into a contract with you).In this case, the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship; or
It is in our legitimate interests for the conduct of our business activities (for example, to communicate with you in a 'business to business' capacity in order to promote our products and services that we believe will be of interest to you or your company).In that regard, we may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company; or
You consented to receive our marketing communications via e-mail as an individual at our clients/companies.
In this case, we will send you marketing communications to develop or maintain a business relationship in accordance with applicable electronic and marketing communications laws. These communications may include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click on.
We will usually offer you a check box on the forms we use to collect your personal data. If you agree to receive the communications, you must click the box.
How to unsubscribe?
In any case, where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the bottom of the marketing email. You can also exercise your opt-out right at any time by contacting us using this form (please indicate the marketing communications you would like to opt out of receiving in the Request Details field).
Please note that it may take up to three days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request. Your opt out will not affect transactional / service emails from us, such as password reset emails or notifications of updates to our terms. You will still receive these as part of your services.
Do we use artificial intelligence?
Yes, we do use artificial intelligence (AI) at times. However, we do not use your personal data in any automated decision making (a decision made solely by the creation and application of technologies without any human intervention) or profiling (processing of personal data with a range of technologies that reduce human intervention to evaluate certain conditions about an individual) that produces a legal effect or similarly significant effect concerning you.
We use a range of technologies to analyze data. In case of our websites, we might use your search terms to recommend particular job offerings. In all cases, there is always human intervention in these processes, as we use these tools to support our expert human decision makers.
Do we share your data with third parties?
We share personal data with a carefully selected list of trusted business partners to provide our services, and to fulfil our contractual obligation to our customers for the purpose set out at section 4 above.
The table below outlines the category of third parties we might need to share your personal data with, and business purpose for doing so. We will obtain your consent to any disclosure of your personal data where required by law.
Recipients | Reason for sharing |
Adecco Group Companies | · To provide IT support by the relevant Adecco Group companies who provide IT functions globally; · For the purposes previously described or to propose offers to you adapted to your profile where you have expressed an interest in local or international opportunities in that market, or Adecco Group companies identify that you may have particular skills required or helpful in that market. |
Service Providers | To enable third parties to provide services to you on behalf of LHH as necessary:
|
Corporate Transaction Partners and related professional advisors | In connection with the sale, assignment or other transfer of all or part of our business. |
Government authorities or law enforcement | If we in good faith believe we are compelled by any applicable law, regulation, legal process or government authority, or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies. |
Other third parties | · To protect LHH’s rights or property; · To protect LHH, our other customers, or the public from harm or illegal activities; · To respond to an emergency which we believe in good faith requires us to disclose personal data to prevent harm; or · With your consent, such as for social events hosted by LHH or The Adecco Group. |
Do we transfer or store your data outside of your home country?
Your personal data can be transferred stored and/or processed in one or more other countries, in- or outside your country of residence. A full list of the countries in which we operate is available on our website at www.adeccogroup.com/worldwide-locations.
We shall only transfer data to those parties set out in section 9 above who are outside your country of residence:
To countries which the European Commission, or the UK Information Commission or the Swiss Federal Data Protection and Information Commissioner or the applicable data protection authority of your country of residence believes offers an adequate level of protection to you pursuant to the relevant data protection provisions, or;
Where we have put in place appropriate safeguards to seek to preserve the privacy of your information, for which we usually use one of the forms of data transfer contracts approved by the European Commission, or the Information Commissioner’s Office (ICO) for the UK or the Swiss Federal Data Protection and Information Commissioner, or the relevant data protection authority of your country of residence as applicable.
Privacy Shield Notice for personal data transfers to the United States
LHH complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data (as defined below) from the European Union, United Kingdom, and Switzerland, as applicable to the U.S., in reliance on Privacy Shield. LHH has certified to the U.S. Department of Commerce that that it adheres to the Privacy Shield Principles with respect to such Personal Data. To learn more about the Privacy Shield Principles, and to view our certification page, please visit https://www.privacyshield.gov/.
Following recent decisions invalidating the adequacy of Privacy Shield, we no longer rely on Privacy Shield for cross-border Personal Data transfers. LHH uses other bases, such as standard contractual clauses for cross-border Personal Data transfers from another entity to us.
This Privacy Shield Notice applies to Personal Data transferred from the European Union, United Kingdom, and Switzerland to LHH in the U.S. in reliance on the respective Privacy Shield framework and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU General Data Protection Regulation (GDPR).
In compliance with the Principles, LHH commits to resolve complaints about our collection or use of your personal data. European Union and the United Kingdom and/or Swiss individuals with inquiries or complaints regarding LHH’s Privacy Shield Privacy Notice should first contact LHH directly at privacy@lhh.com. For complaints that cannot be resolved, LHH commits to cooperate with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the panel or Commissioner about personal data transferred from the EU, the UK or Switzerland.
In order to facilitate the handling of complaints, individuals in the EU can choose to contact their national DPA or use this form. Individuals in the United Kingdom can click here for the United Kingdom Information Commissioner. Individuals in Switzerland can click here for the Swiss Information Commissioner. This independent dispute resolution process is provided at no cost to the individual.
Under certain conditions an individual may choose to invoke binding arbitration to resolve any residual complaints not resolved by LHH, or the DPAs, ICO or FDPIC, as appropriate. If an individual formally invokes binding arbitration, LHH will follow the terms set forth in Annex 1 of the Privacy Shield Frameworks. You can read here about binding arbitration.
As explained in the Privacy Notice, we sometimes provide personal data to third parties to perform services on our behalf. If we transfer personal data received under the Privacy Shield to a third party, the third party's access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.
LHH is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) for compliance and enforcement of the Privacy Shield and Swiss Privacy Shield. LHH is also committed to cooperating with EU, UK, and Swiss data protection authorities. We may be required to disclose personal data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
What data security measures do we have in place?
We have put in place security measures to prevent your information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed while it is under our control.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
While we take appropriate technical and organizational measures and have in place physical and electronic procedures necessary to safeguard the personal data that you provide to us, no transmission to or from us by post, email, phone, SMS (text) message or over the internet can ever be guaranteed as entirely secure.
Communications over the web are not completely secure and for this reason, any transmission is at your own risk.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
What are your rights regarding your personal data?
Under applicable data protection laws, you may have some of the following rights:
Right to be informed about collection or disclosure of your personal data
You have the right to be informed of the categories of personal data that we collect about you as well as the categories of sources from which the personal data was collected.
You also have the right to be informed of the business or commercial purposes for which we use, disclose your personal data as well as the categories of third parties with whom we share that personal data, as mentioned in this Privacy Notice.
Right to access and obtain a copy of your personal data
You have the right to request to have access to the personal data that we collected about you and obtain a copy of them under certain circumstances.
Right to correct your personal data
If you can demonstrate that the personal data we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
Right to be forgotten or to delete personal data
In certain circumstances, you have the right to have your personal data deleted. You may make such a request at any time, and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal data deleted must be granted, we will do so within the time limit set by the applicable data protection laws.
Right to restrict or object to the processing of your personal data
In certain circumstances, you have the right to obtain restriction of the processing of your personal data, or to object to certain processing thereof on grounds relating to your situation.
Right to data portability
This only applies to the information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.
Right to opt-out from marketing communications and newsletters
Where we send marketing to you, you may opt out by using the ‘unsubscribe’ or submitting this form.
Right to withdraw consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to lodge a complaint
You have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal data has arisen.
You are not required to pay for exercising your rights.
If you want to exercise any of your rights, please use our form by submitting this form.
California Notice at Collection
If you reside in California, we are required to provide additional information to you about how we use and disclose your information. We have included this California-specific information below.
Categories of Personal Information LHH Receives: LHH may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the “What categories of personal data does LHH collect and use?” section: identifiers (such as in Identity Data, Contact Data); commercial information (such as in Professional Data); internet or other electronic network activity information (such as in Usage Data and Technical Data); audio, electronic, and visual information (such as in Usage Data); education information (such as in Professional Data); inferences we derive from the preceding or other information we collect. The categories of data that LHH collects and discloses for a business purpose may also include “sensitive personal information” as defined under the California Privacy Rights Act. However, LHH does not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.
Sources: We receive information from sources as described in the “How do we get your personal data and do you have to give them to us?” section, including: from you (including through your use of our products and services), from publicly available sources and from trusted third-party partners as described in the “Do we share your data with third parties? “ section.
LHH’s business and commercial purposes for use: LHH uses personal data for the following business and commercial purposes: to provide LHH Products and Services; for Product Research and Development; for Marketing and Promotions; for Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons. For more information, and the Categories of third parties to whom we disclose Personal Information for business purposes, please see the “Do we share your data with third parties?” section.
LHH may permit analytics services to analyze your interactions with our website, which may constitute a “sale” or “sharing” of data under California law. See our “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.
Retention: LHH retains personal data for as long as required to engage in the uses described in this Privacy Notice unless a longer retention period is required by applicable law.
California & Other U.S. State Privacy Rights
Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have rights to:
Access the categories and specific pieces of personal data LHH has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom LHH has shared personal data;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes.
We do not sell your personal data in the conventional sense. However, like many companies, we may use analytics services that are intended to analyze your interactions with our website, based on information obtained from cookies or other trackers, including for delivering interest-based content to you.
You can opt out of the use of cookies on our website by using your browser
Most browsers allow you to view, manage, delete, and block cookies for a website. You can find specific guidance on how to control cookies for common browsers linked below:
For information on additional browsers and device types please see http://www.aboutcookies.org/or http://www.cookiecentral.com/faq/
To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit
Managing Analytics cookies
You can opt-out of having your anonymized browsing history within our websites or applications recorded by analytics cookies. We use the following service provider on certain of our websites and you can learn more about their privacy policies and how to opt-out of their analytics cookies by clicking on the link:
Google Analytics : Google’s Opt-Out page
You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings
Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing privacy@lhh.com.
LHH will not discriminate against you for exercising any of these rights.
Sensitive Information. In limited instances, LHH receives information that may be considered sensitive under some laws.
Under CPRA "Sensitive personal Information" means any personal information that reveals:
a consumer's social security, driver's license, state identification card, or passport number;
a consumer's account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
a consumer's precise geolocation;
a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership;
the contents of a consumer's mall, email and text messages, unless the business Is the intended recipient of the communication;
a consumer's genetic data; and
the processing of biometric information for the purpose of uniquely identifying a consumer;
personal information collected and analyzed concerning a consumer's health; or
personal information collected and analyzed concerning a consumer's sex life or sexual orientation.
Sensitive personal information that Is "publicly available" is not be considered sensitive personal information or personal information.
LHH processes sensitive personal information to provide LHH products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. LHH does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require LHH to provide a right to limit under the CCPA.
Profiling
Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. LHH does not engage in this type of profiling of individuals.
To exercise your rights, please fill in this form. or email privacy@lhh.com.
To opt out of the use of cookies on our sites, follow the instructions above.
If you would like to submit an opt-out request for personal information that is not collected by cookies – such as your email address - please fill in this form.
These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
Disclosure of Privacy Rights Requests
The CCPA requires businesses to disclose the number of requests received, complied with in whole or in part, or denied.
Between January 1, 2021, and December 31, 2021, LHH received 67 privacy rights requests from USA data subjects which were fulfilled in whole or in part, and 1 privacy rights request which was denied. On average, all privacy rights requests were responded to within 10 days.
Examples of denied requests include requests that were not verifiable, requests that were not made by the consumer, and requests that were exempt from disclosure.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
How do we handle changes to this Privacy Notice?
The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this Website or contacting you using other communication channels.
Getting in touch with us
If you have questions about data protection or if you wish to contact our Data Protection Officer, email us at privacy@lhh.com.
To exercise any of your rights related to your personal data, please fill in this form.