Privacy Policy

This privacy policy explains how and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure in accordance with the General Data Protection Regulation (GDPR).

Who are we?
Hill Robinson is the leading independent yacht management service provider, offering unparalleled services to international clientele worldwide to assist in running yachts safely and efficiently. Hill Robinson’s services include: yacht sale and purchase; yacht management; yacht charter management (including sales); new build and refit project management; technical support; operational support; safety management; financial management (including budgeting and accounting); crew services (including selection, recruitment, employment and administration); client funds administration (including bank accounts and payment cards); property management; estate management; procurement; special projects and major projects; VSAT services; aircraft management; corporate management and administration; company secretarial; VAT registration and compliance; and Regulatory compliance.

This privacy notice applies to the following companies and subsidiaries: Hill Robinson Group Ltd; Hill Robinson International Ltd (UK); Yacht Management Consultants SARL; Hill Robinson International Inc; Hill Robinson Yacht Management Ltd; Hill Robinson España S.L.; Hill Robinson Asia Pacific Pty Ltd.; Moravia Yachting SAM; Hill Robinson International Ltd (IoM); Hill Robinson Saudia; Hill Robinson Estates Ltd; Hill Robinson Aviation Ltd; Hill Robinson Communications Ltd; Hill Robinson Special Projects Ltd; Hill Robinson Admin Ltd; Hill Robinson Services Ltd.

Hill Robinson is committed to protecting the privacy and security of your personal information.

Hill Robinson Group Ltd at 201 Haverstock Hill, Belsize Park, London, NW3 4QG, UK is the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

What type of personal information is collected about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.

The personal information we collect, store, and use about you might include the following categories:

Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
Date of birth.
Gender.
Nationality.
Education.
Marital status, including spouse/partner and dependants.
Next of kin and emergency contact information.
Social security number(s) and payment details.
Bank account details, payroll records and tax status information.
Salary, annual leave, pension and benefits information.
Start and end dates for periods of employment or other work.
Location of employment or workplace.
Information relating to and/or contained in (including copies of) certificates of competence, licences or other professional qualifications held.
Information relating to and/or contained in (including copies of) driving licence.
Information relating to and/or contained in (including copies of) passport, identity card and/or other form of identification.
Immigration status, including information relating to visas.
Recruitment information (including copies of right to work documentation, previous employment details, references and other information included in a CV or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, training records and professional memberships).
Compensation history.
Performance information.
Disciplinary and grievance information.
CCTV footage and other information obtained through electronic means such as swipecard records.
Information about your use of our information and communications systems, including your IP addresses.
Photographs.
Details of any visible tattoos.
Dates on which you make contact with us.
We may also collect, store and use the following “special categories” of more sensitive personal information:
Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
Trade union membership.
Information about your health, including any medical condition, health and sickness records, smoking habits, alcohol consumption and drug use.
Genetic information and biometric data.
Information about criminal convictions and offences.

How do we collect personal information from you?
We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for or with us.

We may obtain personal information about you (or your business) from other companies within the Hill Robinson group of companies and/or from these sources:

when you contact us about products and services;
when you use our products and services;
when your employer contacts us about products and services;
when your employer uses our products and services;
when another client (or prospective client) contacts us about products and services;
when another client uses our products and services;
when you use our website, mobile device apps or social media;
when you talk to us on the telephone;
when you write to us, including by email or letter;
when you send it to us (e.g. in connection with our crew placement services);
in meetings or interviews;
from your business card;
from social media; and
from advertisements.

We may also obtain personal information about you (or your business) from third parties that we work with, including:

Companies that introduce you to us;
Financial advisers;
Credit reference agencies;
Insurers;
Retailers;
Social networks;
Fraud prevention agencies;
Payroll service providers;
Land agents;
Public information sources such as companies registries;
Agents working on our behalf;
Market researchers;
Medical practitioners*; and
Government and law enforcement agencies.

*In some circumstances, we may ask your doctor or other medical professional to send us a report. We will only do this if we get your consent first.

How will we use information about you?
Your privacy is protected by law. We will only use your personal information when the law allows us to. This includes sharing it outside the Hill Robinson group of companies. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform a contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where you consent to it.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information.

We need all the categories of information in the list above:

to allow us to perform our contract with you;
to enable us to comply with legal obligations; and/or
to pursue legitimate interests of our own or those of third parties, provided that your interests and fundamental rights do not override those interests.

A legitimate interest is where we have a business or commercial reason to use your personal information, whether for our own purposes or for those of third party. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of ways in which we may use your personal information, and which of the reasons we rely on to do so. This list is not exhaustive. This is also where we tell you what our legitimate interests are.

TABLE

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations
We will use your particularly sensitive personal information in the following ways:

We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
We will use information about your physical or mental health, or disability status, where necessary to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy 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 allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions where we are legally able to do so.

Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where we have notified you of the decision and given you 21 days to request a reconsideration.
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Who has access to your personal information?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

We will not sell or rent your personal information to third parties. We will not share your personal information with third parties for marketing purposes.

We may share your personal information with companies within the Hill Robinson group of companies and these other organisations or people:

Our third-party service providers, agents subcontractors and other associated organisations and people who we use to help provide you with our products and services;
Our third-party service providers, agents subcontractors and other associated organisations and people who we use to help provide your employer with our products and services;
Our third-party service providers, agents subcontractors and other associated organisations and people who we use to help provide another client with our products and services;
Revenue and customs authorities, regulators and other authorities;
Any party linked with you or your business’s product or service;
Crew employment service providers;
Recruitment agencies;
Job boards and job aggregators, where it helps us to find work opportunities for you;
IT and website developers;
Individual yacht-owning companies;
Yacht captains and crew managers;
Aircraft pilots;
Organisations or people we have a joint venture or agreement to co-operate with;
Organisations or people that introduce you to us;
Organisations or people that we introduce you to;
Organisations or people you ask us to share your data with.

However, when we use third party service providers we disclose only the personal information that is necessary to deliver the products and services and we have a contract in place that requires them to keep your personal information secure and not to use it for their own direct marketing purposes.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal information in order to comply with any legal obligation or to protect the rights, property or safety of our clients. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Transferring your personal information outside of Europe
As part of the products and services we offer or in order to perform our contract with you, your personal information may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. These countries may or may not have similar data protection laws to the EEA. If we transfer your personal information outside of the EEA in this way, we will take steps to ensure that it is protected in the same way as if it was being used in the EEA, by using one of these safeguards:

Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.

How long do we keep your personal information?
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 legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We review our retention periods for personal information on a regular basis.

We are legally required to hold some types of personal information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity and in any event for at least as long as you continue to be employed or engaged by us, to be the recipient of our products and services, to be employed by someone who is the recipient of our products and services or to have a connection with another client who is the recipient of our products and services.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information
Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

There may be legal or other official reasons why we need to keep or use your personal information.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer at Hill Robinson International Ltd, 201 Haverstock Hill, Belsize Park, London, NW3 4QG in writing.

No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer at privacypolicy@hillrobinson.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Review of this Privacy Policy
We keep this privacy policy under regular review. This privacy policy was last updated in December 2019.

We may change this privacy policy from time to time and we will publish any new privacy policy on our website when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Any questions regarding this privacy policy and our privacy practices should be sent by email to privacypolicy@hillrobinson.com or by writing to Hill Robinson International Ltd, 201 Haverstock Hill, Belsize Park, London, NW3 4QG.

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