India Prospective Personnel Privacy Notice

Last Updated September 2025
 

1. Scope

This privacy notice applies to prospective personnel of Hartford Global Services Private Limited ("we, us, our").
 
We may update this privacy notice at any time and any revisions will be posted in here on our company website and on our career page. It is important that you read this notice and any subsequent revisions, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.
 

1.1. What is the purpose of this privacy notice?

We are committed to protecting the privacy and security of your personal data. This privacy notice describes how we collect and use personal data about you during and after your prospective relationship with us, in accordance with applicable data protection laws.

To the extent we are collecting and using your personal data as your prospective Employer, we are a data controller. As a data controller, we are responsible for deciding how we hold and use personal data about you. This notice provides you with information regarding the processing we carry out on your personal data.
 

Index

  1. Scope
    1.1 Purpose
  2. Personal data processing
  3. Change of purpose
  4. If you fail to provide personal data
  5. How we share your personal data
    5.1 Disclosures between us and our affiliates
    5.2 Disclosures to third parties
    5.3 Other reasons why we may disclose your personal data to third parties
  6. How we secure your personal data
    6.1 Transferring personal data outside India
  7. How long do we retain your personal data?
  8. Data accuracy and your duty to inform us of changes
  9. Your rights regarding your personal data and how to exercise them
  10. What we may need from you to confirm your identity
  11. Contact for data protection questions
  12.      Changes to this privacy notice
  

2. Personal data processing

Except where prohibited by law, we may collect, store, and process the following categories of personal data and use it in connection with your application for employment  with us for the purposes stated here:
 

Category of personal data

Purpose for processing

Legal bases for processing

Prospective employees/applicants

 

 

Contact and identifying information: such as name (including spouse and parent’s last name), title, addresses, phone numbers, and personal email address or  mail ID , date of birth, gender, ethnicity and nationality, a copy of your identification documents such as your passport, identity card, Aadhaar, PAN, UAN Number, or birth certificate; photographs and video recordings;

Recruitment information: Résumé/CV and accompanying documents, such as work permit related documentation, qualification information, references and reference check information, and other information that you may include in your Résumé /CV or cover letter or as part of the application process

We will process this information in connection with your application for employment, for the purpose of contacting you,  checking you are legally entitled to work;  and evaluating your fitness for the position for which you have applied, in making a decision about your recruitment or  becoming an employee; for the purpose of administering and maintaining personnel records and your employment agreement with us; and determining the terms on which you work for us, including administering the agreement we have entered into with you; and to carry out our legal obligations or exercise specific rights in our role as a potential employer  in the field of employment law.

 

Consent, or for the specified purpose for which you have provided your personal data and which you have not indicated to us that you do not consent to the use of that personal data; or as otherwise permitted by applicable law.

Information about criminal convictions and offenses

We will use information about criminal convictions and offences:

To make decisions about your application and/ or continued employment by us;

In determining your ability to perform a role in the department or environment in which you work or are applying for work; and

In complying with our regulatory reporting obligations.

Where it is necessary in relation to legal claims, where it is necessary to protect your or our interests and you are not capable of giving your consent, or where you have already made the information public.

Consent, or for the specified purpose for which you have provided your personal data and which you have not indicated to us that you do not consent to the use of that personal data; or as otherwise permitted by applicable law.

Data regarding your access to our building and offices.

 

Compliance with security and other mandatory policies and building access.

As permitted by law we will process this data as permitted under law for employment related purposes, including carrying out our legal obligations or exercising specific rights in our role as an employer  in the field of employment law, and where we may need to protect your or our vital interests.

Biometric information , e.g., fingerprints, facial scans

 

Biometric information is used to establish identity, and may be processed by our background check vendor in connection with background checks.

 

Consent, and further we will process the data you provide for the specified purpose for which you have provided your personal data to us and in respect of which you have not indicated to us that you do not consent to the use of your personal data; also as permitted under law for employment related purposes, including to carry out our legal obligations or exercise specific rights in our role as an employer (including as the data subject’s former employer) in the field of employment law.

 

 

3. Change of purpose

Unless otherwise permitted under law, we will only use your personal data 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 data for an unrelated purpose, we will notify you and if required we will request your consent or explain the legal basis which allows us to do so.
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above disclosures, where such processing is required or permitted by law.
 
 

4. If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to process your application or inquiry regarding employment or we may be prevented from complying with our legal or regulatory obligations (such as ensuring your health and safety).
 
 

5. How we share your personal data

Unless otherwise permitted under law, we will only use your Personal Data 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 Data 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 Data without your knowledge or consent, in compliance with the above disclosures, where this is required or permitted by law.
 
 

5.1 Disclosures between us and our affiliates

We may share your personal data with our affiliated companies for the reasons stated in the purposes of processing stated above. We may also share your personal data with our affiliates as part of our regular business and reporting activities, in the context of a business reorganisation or group restructuring exercise, for system maintenance support, for hosting of data and for other legitimate business reasons, including data analysis, business development, forecasting, strategy assessment, resource planning, general business operations, mergers and acquisitions, strategic sourcing, real estate, restructuring and related organizational purposes.
 
 

5.2 Disclosures to third parties

We may have to share your personal data with third parties, including our third-party service providers ("Third Parties").
 
The following are the types of activities carried out by Third Parties:
 
  • human capital management administration
  • provision and administration of recruitment assessments, training, and professional development
  • library and research services such as subscriptions and memberships
  • building security access and maintenance
  • travel services providers
  • telecommunications and messaging services such as our business continuity emergency notification system
  • consultants such as talent management and law firms
  • hard copy archiving; and 
  • IT services including systems providers for meetings, communications (including telephone, messaging, and email), productivity applications, document management, and security
 

5.3 Other reasons why we may disclose your personal data to third parties

We may also disclose your personal data:
 
 
  • to comply with a legal or regulatory obligation, where such disclosure is required by a tax authority, or our regulators or supervisory authorities, the police, or a court of competent jurisdiction
  • where it is necessary to administer the contract, working relationship and any associated benefits with or for you 
  • for the purposes of auditing, insuring and in the course of seeking advice with regards to our business operations and claims handling; or
  • where we have another permissible purpose under applicable law
 

6. How we secure your personal data

The protection and security of your personal data is important to us. We implement appropriate technical and organisational measures in compliance with the law to protect your personal information against accidental or unlawful destruction, loss, change or damage. Where we transfer personal information to our service providers, we will ensure that the recipients also implement appropriate technical and organisational security measures to protect your personal information. We do not allow our service providers to use your personal data for their own purposes; we only permit them to process your personal data for specified purposes and in accordance with our instructions.
 
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access your data. They will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
 

6.1 Transferring personal data outside India 

Personal data that we collect about you may be transferred to, and stored at, or processed in one or more countries outside India, including the United Kingdom and the U.S.A. by individuals who work for us or our service providers. In such cases, we will take appropriate steps to ensure compliance with any applicable data transfer requirements.
 
You can contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights at ConsumerDataInquiries@thehartford.com.
 
 

7. How long do we retain your personal data?

We retain your personal data pursuant to our Records Management Policy and Schedule which have been designed to ensure that we maintain personal data for that period of time necessary for the purposes for which we collected the data, and also to ensure that we comply with all applicable statutory and regulatory requirements for retaining records, including personal data.
 
 

8. Data accuracy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please use your Candidate Profile Account to keep us informed of any changes to your personal data during your relationship with us.
 
 

9. Your rights regarding your personal data and how to exercise them

Under certain circumstances, by law you have the following rights:
 
a. The right to information/access – you have the right to know what personal data is being processed, for what purpose, and by whom.
b. The right to request copies of your personal data.
c. The right to correction and erasure
     i.  The right to rectification – you have the right to request that we correct any information you believe is inaccurate.
     ii.  The right to erasure – you have the right to request that we erase your personal data which is no longer necessary or for which consent has been withdrawn in accordance with applicable law, under certain conditions.
d. Right to grievance redressal – We have an obligation to provide a mechanism for individuals to raise complaints and seek resolution. Privacy related complaints should be addressed to consumerprivacyinquiriesmailbox@thehartford.com
e. Right to withdraw consent - In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data 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 us at the email noted below.. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, and unless we have another lawful basis for continuing to process your personal data, we will dispose of it securely.
f. Right to Nominate- Individuals can nominate another person to exercise their rights in case of death or incapacity.
 
If you want to exercise the above rights, please contact consumerprivacyinquiriesmailbox@thehartford.com.
 
If you are dissatisfied with any aspect of our handling of your personal data, you have the right to make a complaint at any time to the relevant local data protection/government authority.
 
Back to Index
 

10. What we may need from you to confirm your identity

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 an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
 
 

11. Contact for data protection questions

If you have any questions about this privacy notice or how we process your personal data, please contact us at consumerprivacyinquiriesmailbox@thehartford.com.
 
 

12. Changes to this privacy notice

We reserve the right to amend this privacy notice at any time, and we will make a new privacy notice available herewhen we make any substantial updates.