Who We Are
This Privacy Notice applies to Hudson Talent Solutions, LLC, registered at Suite 101, 53 Forest Ave, Old Greenwich, CT 06870, USA, a subsidiary of Star Equity Holdings Inc., and its subsidiaries and affiliated entities (Hudson, We, Us, and Our) that collect, use, disclose or otherwise process personal data in connection with their business operations globally.
At Hudson, we respect your privacy and are committed to protecting it through compliance with the practices described in this Privacy Notice.
Depending on the nature of the services provided, Hudson may act either:
as a controller of personal data, where we determine the purposes and means of processing personal data; or as a processor or service provider acting on behalf of our clients and processing personal data in accordance with their instructions.
For example, Hudson generally acts as a controller in relation to its own recruitment activities, talent pooling, business operations, compliance obligations and workforce management. Hudson may, however, act as a processor or service provider where it processes personal data solely on behalf of a client as part of recruitment process outsourcing (RPO), managed service provider (MSP) or similar service arrangements.
Where Hudson acts as a processor or service provider on behalf of a client, the provisions of this Privacy Notice that relate solely to Hudson’s role as a controller do not apply. In those circumstances, the relevant client may provide its own privacy notice and will be responsible for determining the purposes and means of processing your personal data. Hudson will process your personal data only in accordance with that client’s instructions and any applicable legal requirements.
This Privacy Notice describes how we collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants only and to the personal data collected through our recruitment processes, regardless of the country where you are located.
Our recruitment website may include links to third-party websites, plug-ins, services, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the Privacy Notice of every website you visit or service you enable.
Please read this Privacy Notice carefully to understand our policies and practices for processing and storing your personal data. We will only process your personal data as described in this Privacy Notice unless otherwise permitted by applicable laws. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes. This Privacy Notice may be updated from time to time (see Changes to Our Privacy Notice).
How We Collect Data About You
We use different methods to collect data from and about you including through:
- Direct applications and interactions: You may give us information about you by directly applying for roles via our website or reaching out to us by email or via social media.
- Publicly available sources: We may receive information about you from publicly accessible information, for example, from your CV posting on Job Boards or from publicly accessible profiles (such as LinkedIn). We will always make initial contact with you to seek permission before we enter your information into our recruitment systems. Your preferences will always be respected.
- Third party job sites: If you apply for one of our roles on a third-party website your information will be shared with us for the purpose of processing your application.
- User contributions: You also may provide information for us to publish or display (post) on public Website areas or transmit to other Website users or third parties, such as commenting on, or providing content for Hudson’s social media (collectively, User Contributions). You submit User Contributions for posting and transmission to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any website users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
Data We May Collect About You
For purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal data in connection with our recruiting activities.
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Work history and other relevant information, including information contained in a resume, CV, cover letter, or job application.
- Education information including degrees awarded, transcripts, and other information provided in support of the job application.
- Compensation history.
- Information collected during screenings, interviews and competency or psychometric tests.
- Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
- Reference information and information received from immigration and background checks, where applicable, including information provided by third parties.
- Information related to previous applications to Hudson Talent Solutions or previous employment history with us.
- Any information you share with us to enable reasonable adjustments or to monitor our processes in line with anti-discrimination and equality laws (see Collection and Use of Sensitive Personal Data).
- Technical and messaging metadata, such as timestamps, delivery status, and platform identifiers when you interact with our AI screening solution.
- Any additional personal details that you feel necessary to voluntarily provide to us.
The provision of full and complete information in support of a job application is necessary for selection purposes. Failure to provide any of the data may affect the processing and outcome of your application.
Collection and Use of Sensitive Personal Data (or Special Category Data)
The following categories of personal data may be considered sensitive under the laws of your jurisdiction and may receive special protection:
- Race or ethnic origin
- Political opinions
- Religious, philosophical, or moral beliefs
- Trade union membership
- Social welfare, sexual life, or sexual orientation
- Physical or mental health or condition
- Unlawful or objectionable conduct, criminal charges, or convictions
- Biometric information; and
- Genetic data.
We may collect and process the following categories of sensitive personal data when relevant for a particular position and as permitted by applicable law:
| Special Category Personal Data | Condition for Processing | Purpose |
|---|---|---|
| Health data | Employment Law GDPR, Article 9(2)(b) | Reasonable Adjustments We may use information about your health or disability status to consider whether we need to provide reasonable adjustments to your recruitment or interview process (e.g., if you are disabled). |
| Ethnicity Religious or Philosophical Beliefs Health data Sexual Orientation | Substantial Public Interest GDPR, Article 9(2)(g) | Equal Opportunity Monitoring We may use information about your ethnicity, religious or philosophical beliefs, health data (including any disabilities), or sexual orientation, for equal opportunity monitoring and reporting purposes, in accordance with applicable law or best practice. |
Where we have a legitimate need to process your sensitive personal data for purposes not identified above, we will only do so only after providing you with Privacy Notice and, if required by law, obtaining your consent.
Depending on the jurisdiction in which you operate and on your specific role, we may collect information about your criminal convictions and offences if we offer you a position with us and you accept (conditional on checks and any other conditions, such as references, being satisfactory). We do this to satisfy ourselves that there is nothing in your criminal convictions and offences history which makes you unsuitable for the role. 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.
We have in place appropriate policies and safeguards which we are required by law to maintain when processing such data.
Our roles and recruitment processes are not directed to minors. As a general threshold, we do not intentionally process personal data of individuals under the age of 16, though the applicable minimum age may vary depending on the laws of your jurisdiction. If you are a parent or guardian and believe we have collected information about your child, please contact us and we will take steps to delete the information as soon as practicable.
How We Use Your Personal Data
We only process your personal data as described in this Privacy Notice or as otherwise required or permitted by applicable law in connection with carrying out our recruitment process. Under the UK and EU GDPR, these constitute the lawful bases of our processing. We may process your personal data for the following purposes.
| Activity | Lawful Basis |
|---|---|
| Posting of active job opportunities on our website or other relevant job sites | Legitimate interests (to make candidates aware of new opportunities) |
| Sourcing candidates from public sources (i.e. LinkedIn, Job Boards etc.) | Legitimate interests (to locate potential candidates for roles) |
| Processing applications via direct entry or inputting your details into our applicant tracking system | Legitimate interest to process an application where you have applied for a position. |
| Inputting your details into our applicant tracking system where your details are publicly available (e.g. job boards, LinkedIn) | Consent |
| Following up on open positions using SMS or WhatsApp where you have provided your mobile number | Consent |
| Automated screening via SMS & WhatsApp | Consent |
| Alternative manual screening at your request | Legitimate interests (to screen for suitable candidates for the role at the initial stage of application) |
| Psychometric or similar testing | Legitimate interests (to ensure that the candidate is the correct business cultural fit for the role and our organization) |
| CV evaluation (both automated and manual) | Legitimate interests (to ensure the candidate has the necessary competency and experience to fulfil the role advertised) |
| Shortlisting candidates (automated or manual review, at your request) | Legitimate interest (to ensure the correct candidates progress) |
| Reasonable adjustments to accommodate for any candidate needs | Legal obligation |
| Interviews | Legitimate interests (to find out more about the candidate and their experience to determine whether they would be a suitable appointment) |
| Documenting feedback | Legitimate interests (to provide feedback to the candidate if requested) |
| Undertaking references, background checks and criminal records checks | Legitimate interests (to establish suitability within the role) |
| Equal opportunity monitoring | Public interest; |
| Formal offer | Contract |
| Retention of unsuccessful candidate details in case of future opportunities | Consent |
| Use of AI and automated decision making to support the process | Legitimate interests (see the Use of AI section below) |
We will only process your personal data for the purposes for which we have collected it, unless otherwise required or permitted by applicable law. If we need to process your personal data for an unrelated purpose, we will provide Privacy Notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent where required by applicable law or regulation.
In some circumstances, we process personal data where it is reasonably necessary for our legitimate business interests, including recruitment-related activities. When we do this, we consider the potential impact on your privacy and take steps to ensure your personal data is handled fairly and responsibly, in line with your reasonable expectations as a candidate.
Use of SMS messaging and WhatsApp
- Your consent to receive recruitment-related messages via SMS or WhatsApp will be obtained at the point of data collection, before any messages are sent. We will record your consent, including the date and method by which it was given. You may withdraw your consent at any time by replying STOP to any message or by contacting us using the details below. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal and will not affect the consideration of your application by other means. We will ensure we provide clear disclosures at the point of data collection, including:
- the purpose of the messages
- expected message frequency
- opt-out instructions; and
- confirmation that consent is not a condition of applying for a role.
Conversations take place via standard mobile text messaging using our messaging infrastructure and approved aggregator partners and, details are as follows.
- Standard network messaging or data charges may apply.
- The solution supports standard opt-out (for example, STOP) and help (for example, HELP) keywords.
- Where the SMS channel is enabled for US mobile numbers, messages are sent using 10-digit long code (10DLC) routes under the US carrier framework and The Campaign Registry. US mobile numbers are used solely for the purpose of delivering our recruitment messages and operating the messaging service. We are responsible for ensuring that message content aligns with the registered 10DLC use case.
- We register and maintain the necessary brand and campaign records for our organisation’s messaging traffic and operate the service in line with carrier rules and CTIA messaging principles.
- Conversations may take place via the WhatsApp Business Platform operated by Meta. Use of WhatsApp is also subject to Meta’s own terms and Privacy Notice. The solution supports opt out via STOP and complies with WhatsApp’s messaging rules.
- Where you are based in a jurisdiction outside of the United States, we will ensure we are compliant with the laws and regulations of that jurisdiction.
- These obligations are supported through built-in opt-out handling, suppression lists, message logging, and configurable messaging templates.
Use of AI
We are committed to using Artificial Intelligence (AI) responsibly, transparently, and ethically to empower our people, clients, and candidates. Our approach is guided by our core values and strengthened by governance practices aligned with ISO/IEC 42001, the international standard for responsible AI management. For more information on our responsible and ethical use of AI, please see: Responsible & Ethical Use of Artificial Intelligence – Hudson Talent Solutions. We utilize AI in our legitimate interests to bring efficiency to the process and to increase the quality of any communications you may have with us. As part of processing your application, we will leverage the use of AI to support the application process. We confirm that your data will not be used to train the AI systems we use. AI is used to help support identifying, screening and shortlisting candidates. AI also helps us communicate with you in an effective manner, and to arrange interviews and assessments. To deliver these capabilities, we engage third-party AI service providers, including providers of applicant tracking and screening technology, conversational AI and automated messaging platforms, and candidate assessment and evaluation tools. These sub-processors are subject to written data processing agreements consistent with our obligations under applicable data protection law. A current list of our AI sub-processors may be obtained by contacting us using the details below.
We may use AI-assisted screening questions at the initial application stage to help assess whether candidates meet the key requirements for a role. In some cases, this may automatically determine whether an application progresses to the next stage.
You may request a human review of the outcome at any time. All later stages of the recruitment process involve human review and assessment. You can choose not to use AI-based screening as part of the process and liaise with a recruiter directly, either at the time of submitting your application or subsequently. Choosing not to use AI features will not cause us to treat your application any differently and any decisions will be reviewed by a human in all cases. We are mindful that you may have concerns regarding the use of AI and you may contact us using the details provided if you have any questions.
Disclosure of Your Personal Data
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, supporting our recruitment function, sourcing candidates, obtaining employment verification and background checks. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law.
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect our rights and property, other job applicants, employees, or the public, as required or permitted by law.
- During emergency situations or where necessary to protect the safety of persons.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs.
For additional purposes with your consent where required by law.
International Data Transfers
Where permitted by applicable law, we may transfer the personal data we collect about you to other countries. We will ensure that these countries afford a similar level of protection for your personal data, or that necessary safeguards have been implemented in accordance with the laws of your home country for the purposes set out in this Privacy Notice. You may contact us using the details below to obtain further information about the specific safeguards in place for any given transfer.
How Long Will We Keep Your Information?
We will not keep your information longer than needed for the recruitment process. Please note that retention periods may differ depending upon the country in which the role is based. As a general guide, where your application is unsuccessful, we will retain your personal data for a period of up to 3 years from the date of our last communication with you, unless you consent to a longer retention period for the purpose of being considered for future opportunities. Where you are appointed to a role, your data will be retained in accordance with our employee privacy Privacy Notice. In some circumstances, we may retain your personal data for longer periods where required by applicable law or regulation (for example, to comply with employment, tax, or anti-discrimination legislation). 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 unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. When we are no longer required to keep your information, we will take all reasonable steps to destroy or erase your data from our systems. If you require further information on retention periods applicable to your jurisdiction, please contact us using the details below.
Your Rights
Depending on where you live, you may have certain rights under applicable data protection laws. While these rights can vary by jurisdiction, we strive to honor them globally. These may include:
1. Right to Access
You can request confirmation of whether we process your personal data and obtain a copy of that data.
2. Right to Rectification
You have the right to correct inaccurate or incomplete personal data we hold about you.
3. Right to Erasure (Right to be Forgotten)
You may request deletion of your personal data, subject to legal and contractual obligations.
4. Right to Restrict Processing
You can ask us to limit how we use your data in certain circumstances (e.g., while accuracy is being verified).
5. Right to Data Portability
Where applicable, you can request your data in a structured, commonly used, machine-readable format and transfer it to another controller.
6. Right to Object
You may object to processing of your data for direct marketing or, in some cases, for other legitimate interests.
7. Right to Withdraw Consent
If processing is based on your consent, you can withdraw it at any time without affecting prior lawful
processing.
8. Right to non-discrimination
Under the laws of some jurisdictions, such as the California Consumer Protection Act (CCPA), you have the right not to be discriminated against for exercising your privacy rights.
9. Right to Know and Transparency
You can request details about the categories of personal data we collect, sources, purposes, and third parties with whom we share it.
10. Rights Related to Automated Decision-Making and Profiling
Where applicable (e.g. under GDPR), you have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you.
You may also request:
- Human review of such decisions
- An explanation of the logic involved; and/or
- To contest the decision.
11. Right to Lodge a Complaint
We hope that we can resolve any query or concern you raise about our use of your information. Please use the contact details provided below to contact us with any queries or concerns. You may also file a complaint with your local data protection authority in your jurisdiction if you believe your rights have been violated. For data subjects located in the UK, the relevant supervisory authority is the Information Commissioner’s Office (ICO), which can be contacted at www.ico.org.uk For data subjects located in the EEA, you may contact the data protection supervisory authority in your EU member state of habitual residence, place of work, or place of alleged infringement.
How to Exercise Your Rights:
Please contact us at the details below. We will respond in accordance with applicable laws and within required timeframes.
Data Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
Cookies and Automatic Data Collection Technologies
Our website uses cookies or other automatic data collection technologies to distinguish you from other Website users. For more information, please see the Hudson Talent Solutions Cookie Policy: Cookies – Hudson Talent Solutions
Changes to This Privacy Notice
This Privacy Notice is effective from the date stated at the beginning of it. We reserve the right to update this Privacy Notice at any time, and this will be updated via our website and/or our Applicant Tracking System. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with Privacy Notice and, where required by law, seek your consent before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.
Contact Us
Post:
FAO: Data Protection Officer
Hudson Talent Solutions
One Lochrin Square
92 Fountainbridge
Edinburgh
EH3 9QA
Email: privacy@hudsontalent.com