GDPR and Harri

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Next month, we all face a major regulatory change that will impact the way we manage and store candidate and employee data, due to the General Data Protection Regulation (GDPR).

As these new regulations have the potential to negatively impact the processes of attracting talent and manage hiring, we’re working hard to ensure we are keeping our clients ahead of these changes.

What is the GDPR?

The GDPR is EU-wide legislation that will replace the Data Protection Act 1998 in the UK. Intended to strengthen and unify data protection for all individuals within the European Union (EU), it also addresses the export of personal data outside the EU. The GDPR aims primarily to give control back to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

Although many companies have already adopted privacy processes and procedures consistent with the directive, the GDPR contains a number of new protections for EU data subjects and threatens significant fines and penalties for non-compliant data controllers and processors once it goes into effect.

While not yet required for the Americas, GDPR requirements apply to each member state of the European Union, aiming to create more consistent protection of consumer and personal data across EU nations.

What is the Purpose of the GDPR?

The purpose of the GDPR is to provide a standard set of data protection laws across all member countries so that EU citizens can clearly understand how their data is being used or raise any complaints.

What are the key privacy and data protection requirements of the GDPR?

  • Requiring the consent of subjects for data processing
  • Anonymizing collected data to protect privacy
  • Providing data breach notifications
  • Safely handling the transfer of data across borders
  • Requiring certain companies to appoint a data protection officer to oversee GDPR compliance

What is a Data Controller, and What is a Data Processor?

  •  Data Controller - A controller determines the purposes and means of processing personal data.
  • Data Processor - A processor is responsible for processing personal data on behalf of a controller.

Who is the Data Controller in the Harri-Customer relationship?

Job seekers set up personal profiles within Harri which the job seeker can use to apply for jobs with any and all of Harri’s customers. This data is controlled by Harri until the job seeker deletes the profile. The data is shared with Harri's customers when a job seeker applies for a role with the customer. 

The customer then becomes a controller with regards to any other personal data of the candidate added by the customer during the hiring process. As Harri and its customers both make decisions on how the personal data of the candidate is processed, both Harri and its customer are deemed to be joint controllers.

What is Harri doing to ensure compliance?

Harri takes the protection of personal data very seriously, as it underpins everything we do. We continue to take advice from our legal partners, and we have enlisted the support of industry experts to ensure that we remain compliant.

Here is how we’ll support our customers:

  • An updated Data Sharing Arrangement to reflect GDPR requirements and ensure compliant data transfer with processing outside of the EU and the EEA.
  • New product capabilities to assist in compliance with the rights of the data subject. 
  • Allowing you direct communication to our Data Protection Officer (DPO) simply by emailing

Here is how we’ll support our candidates:

  • Log-In/Sign-Up Disclaimer: When a candidate logs into or signs up for Harri, they will be notified that you, the client, are using Harri as its provider of applicant tracking software. The disclaimer explains that both you and Harri wish to keep and handle their information appropriately. The disclaimer invites the candidate to visit our Fair Processing Notice for more information on how Harri will use their data.  
  • Job Post Disclaimer: When a candidate views a job post, they will be notified that you, the client, are using Harri as its provider of applicant tracking software. The disclaimer explains that both you and Harri wish to keep and handle their information appropriately. The disclaimer invites the candidate to visit our Fair Processing Notice for more information on how Harri will use their data.  
  • Career Portal Job Alerts Disclaimer: When a candidate chooses to receive job alerts, they will receive a disclaimer stating that by clicking ‘submit’ they have chosen their consent to use the provided data to receive job alerts relevant to the positions and job types they have selected. The candidates are notified that if they change their mind and do not want to be contacted with this information, they can unsubscribe or update their preferences. The disclaimer notes that you, the client, are the data controller and will only use the candidates’ data as explained in our privacy policy.
  • E-mail Signature to Walk-In Employees & Uploaded CSVs: If a candidate is a walk-in, they will receive a notification inviting them to see your Fair Processing Notice. They will also be directed to Harri’s Fair Processing Notice if they wish to learn how Harri will use their data. 
  • Fair Processing Notices: We provide candidates with access to our clients’ Fair Processing Notices so our candidates know how you, the client, manage their data.

We look forward to assisting your company in their mission to protect the privacy rights of your employees.




Private Equity Firm Invests in Next Generation Total Talent Solution for Hospitality Industry

ATLANTA, GA – April 17, 2018 – NRD Capital, an Atlanta-based private equity fund, is pleased to announce its minority investment in Harri, LLC (“Harri”).  The technology company, whose mission is to revolutionize employee-facing technology in service industries through its Workforce OS™ platform, was launched in 2013 by Luke Fryer, and is based in New York City.

The newest technology company to join NRD Capital’s diverse portfolio, the Harri Workforce OS™ platform streamlines the full breadth of the employee lifecycle. A unique aspect of the platform is that it has been purpose built for service industry verticals, with an initial focus on the hospitality..

The software offers a full suite of talent-technology solutions, offer over 30 modules in all, such as candidate sourcing, hiring and onboarding, labor management, learning and performance management. Harri’s clients currently include restaurants, hotels and other hospitality businesses. With nearly 500,000 job seekers enrolled and 8,300 employers, Harri’s innovative and intuitive platform maximizes efficiency for all parties.

“As leaders in the franchise and hospitality industries, NRD Capital knows the value in acquiring, retaining, and optimizing top-talent, and we’re confident our investment in Harri will assist in furthering the next generation of total talent solutions for the hospitality industry,” said Aziz Hashim, NRD Capital Founder and Managing Partner.

“In hospitality, people are our greatest resource, but also our greatest challenge. Hospitality businesses of all sizes are grappling with the need to offer their employees technology that is built to embrace labor related challenges, and Harri was built to solve that problem“ said Luke Fryer, CEO of Harri. "This round of funding will allow us to accelerate our investment in R&D and go to market capabilities. It will also support the expansion of marketplace and business intelligence capabilities, plus help us grow the community.”

Harri joins NRD’s extensive portfolio of companies across the hospitality, service/retail and technology industries. For more information about NRD Capital, please visit For additional information about Harri, please visit



About NRD Capital

NRD Capital invests in brands that offer superior products or services and compelling unit-level economics in order to help them strategically grow through the power of franchising. The fund was founded in 2014 by Aziz Hashim, one of the world's leading experts on franchising, with the goal of leveraging operational and financial experience to position high quality brands for accelerated but responsible growth. The differentiated private equity fund takes a unique approach to investing, applying operating expertise and leveraging its wide network of franchisees, in addition to infusing capital in its portfolio companies.

Above All, Remain Calm!

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How to Put Out Workplace Fires Without Losing Your Cool

by Cleo Clarke, VP of HR Strategy & Development at Harri

This article originally appeared in the April 2018 issue of Hospitality Trendz


How many of you have been in situations where you start the conversation with, “You won’t believe this...”

Well, in this month’s article, I would like to share with you three stories that you won’t believe.

As you may already know, I have been in restaurant and hotel Human Resources for more than 20 years, and I’ve seen it all. Below, I’m sharing some of my stories in the hopes that I can help others (please note: real names, hotel, and restaurant locations have been left out to protect identities).

Recruiting: You won’t believe this...

It was a hot summer day in New York City. I was a junior HR professional conducting an interview for a Restaurant Manager. I was down to my last two back-to-back interviews, with both candidates sitting in the waiting area.

I am a huge advocate for candidate experience. I believe it is important to ensure that you are providing a positive and memorable experience for your candidate. (Remember: people share their experiences with their friends, review websites like Glassdoor, and their social media followers!)

I completed the welcome and handed the one candidate a clipboard so he could fill out the application (yes, I said clipboard and application - it was a long time ago and the wonderful technology we have today wasn’t available back then).

The candidate proceeded to fill out the application while I went back in to my office to prepare for the interview. About 5 minutes later, I heard loud music playing (I have to admit - it had some good bass). I walked out of my office to the waiting area, only to find one of the candidates with his shoes and socks off, and a mini stereo system setup.

My first instinct was jump in and get my dance on - but that would be inappropriate.

I can only assume that he took his shoes and socks off because he was extremely hot. I asked him to put his shoes back on. His response? “I’m trying to set the atmosphere, so I’m ready for my interview.”

I explained to him that it was not appropriate and unfortunately, we would not be moving forward in the interview process. As I am sure you could imagine, he was not happy and refused to leave, forcing me to call security to have him escorted out.

The Fix: In these types of situations, it is important to stay calm and ensure that you treat the person with dignity. You never know how fast these situations can go south! Be sure to reach out for assistance and to take a moment to think through your response.

Progressive Discipline Matter: You won’t believe this...

I had an employee at a hotel who was a poor performer. We’ve have all dealt with the “Poor Performer,” but this situation was different because he refused to accept that he was a poor performer.

As you know, it is important to ensure you follow your progressive discipline policy. This gentleman was coached, counseled, and managed throughout the entire process. Finally, he was put on a Performance Improvement Plan, or PIP. Unfortunately, his behavior and performance did not change. Not only that, he was also a very vocal employee who appeared to have some aggression issues.

The day came when we made the decision based on his choice not to correct his behavior or performance that it was time to sever the employment relationship. We were concerned that this situation would escalate….and escalate it did. The manager of the department had asked me to sit in on his termination. Normally as an HR professional you don’t sit in on terminations unless they are egregious or if you have a concern it may escalate. This method allows you to remain unbiased or give the perception of being so.

With the concern that this situation would escalate, we had a Hotel Security officer situated outside the HR office. We were extremely detailed in all the steps: We reviewed the file, had all pertinent documents ready, and made sure that we were also prepared to hear mitigating circumstances that we may not know about.

As we began to go through the details and talk to this employee, we could see the anger begin to grow in his behavior. The moment we shared with him that he was terminated, he jumped up and used both of his hands to clear everything off my desk. With one swipe, from my left to the right, he cleared my desk - computer and all. He began to scream how we were horrible people and this was all our fault. Fortunately, we had the security officer outside, who immediately came in and subdued the employee, who then began to lunge toward me. At that point the employee calmed down and the security office walked him out of the building.

Fortunately, this situation ended with no one harmed - except for my computer.

The Fix: The important thing to remember here is to remain calm and make sure you are prepared. Trust your instinct and know the facts. As I mentioned earlier, this employee had a history of aggressive behavior, so we were prepared.

Payroll Pay Period: You won’t believe this...

We had over one hundred employees who did not get paid!

As employees, the last thing any of us ever wants to hear is, “Sorry, but we don’t have a check for you.” If you have ever been in this situation you know how daunting it is. Paying our employees and ensuring they’re taken care of them is our number one priority. After all, they are our internal customer.

On a cold winter day, we had just opened this particular operation and we were running the very first payroll (I was not at the location as I was traveling for work). I was in the middle of interviewing a senior candidate for another location for the restaurant group and felt my phone vibrating in my pocket nonstop. I realized that something was wrong, reached into my pocket, and saw that I had about 20 missed calls from members of my HR team, payroll, and ownership. I immediately realized something was really wrong and responded to the calls to  learn that that over 100 people were not paid, and that we had a mob of upset employees.

The Fix: If any of you have ever been in this situation, you know how unnerving it can be. It was extremely difficult for the team to not only face all theses upset employees, but to also not completely understand how this happened.

It turns out that it was a technical issue between our applicant tracking system and our payroll system. We had just rolled out a new applicant tracking system, and there were issues that had not been addressed during the implementation.

We definitely learned a few things from this situation:

  1. Always make sure that you follow a detailed implementation process

  2. Ensure you follow through on a pre-implementation process.

  3. Check both sides and make sure the data is transferring.

  4. Complete in-depth testing of your system and the payroll system, just to make sure that everything is functioning correctly.

  5. Lastly, check any small details, just to make sure that your ATS is running exactly how you want it to.

These are just a few stories to share the challenges I have faced over the years. There are a few lessons to learn from all of these situations!

The most important thing to remember is this: Always remain calm. This will allow you to think through the situation and come up with the best plan to resolve it.

Be sure to be respectful in whatever the situation is. Remember that you are dealing with people, and they are the your most valuable asset!

Keeping these steps in mind will ensure you avoid having a story that begins with “You won’t believe this...”


About the Author

Cleo Clarke is the Vice President of Human Resources Strategy & Development at Harri. Clarke is a senior HR professional and has held an executive role in the hospitality industry for more than 15 years. 

Harri Partners with ZipRecruiter

Harri Partners with ZipRecruiter to Help the Hospitality Industry Hire

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Harri is proud to announce our integration with ZipRecruiter, the No. 1 rated job search app on Android and iOS with more than 7M active job seekers each month. Now, employers who post a job on Harri can use Harri’s Job Distributor tool to instantly post that same job on ZipRecruiter.

Details of the Integration

  • An ATS (Applicant Tracking System) integration between Harri and ZipRecruiter
  • ZipRecruiter is now featured in Harri’s Job Distributor tool
  • With one click, Harri employers can display their jobs to the millions of active job seekers who use ZipRecruiter every month

The integration benefits both employers and job seekers. Growing companies can get their jobs in front of more potential hires, while job seekers have a better chance of finding the right opportunities for them. The integration streamlines the hiring workflow for both sides of the marketplace, providing a seamless experience for Harri employers and ZipRecruiter users alike.

Harri’s extensive job seeker network boasts more than 350,000 hospitality-specific candidates across the U.S. and U.K., including major metropolitan areas such such as New York, Los Angeles, Chicago, Las Vegas, Washington, D.C., and Miami. More than 8,300 hospitality brands trust Harri for their workforce management needs.

Hospitality is an industry unlike any other, and its employers require a full suite of hiring tools designed to meet their individual needs. Harri gives them those tools. And through Harri’s integration with ZipRecruiter, those same hospitality employers now have access to another stream of great candidates, so they can hire the people they need effectively and efficiently. 


The "Touchy" Kitchen

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Preventing Workplace Harassment in These Modern Times

by Cleo Clarke, Senior VP of HR Strategy & Development at Harri

This article originally appeared in the March 2018 issue of Hospitality Trendz.


Keeping in line with the relevant and important topics in the news today, I think it’s time to talk about the really “touchy” subject within our own industry; harassment in the workplace - both sexual and hostile.

Talking about this is challenging for many people, myself included, as I have been a part of the hospitality industry for as long as I can remember. In fact, my mother and father, both West Indian immigrants, came to the U.S. and opened several restaurants and businesses so I joke that I was born in to a pot of food.

My love and passion for the hospitality industry is unmatched, as I spend both my professional and personal time enjoying restaurants and sampling and sharing new, delicious and innovative food – which can be seen on my Instagram feed full of food selfies.

With that being said, the hospitality industry is not perfect. There has been a long-standing history of inappropriate behavior - not only in the kitchens of free-standing restaurants, but in hotels as well.

We’ve all heard stories of pots, pans, and knives flying through the kitchen, or chefs yelling at their line cooks. What we haven't spoken about and need to address is the inappropriate sexual predatory behavior that has been going on for years. Inappropriate behavior or sexual misconduct can be as simple as unwanted hugs or repeat kisses on the cheek.

With heavy hitters like Harvey Weinstein, Matt Lauer, and the hospitality industry’s very own Mario Batali being exposed as a serial sexual predators, there is a necessary change coming as his type of behavior has been brought into the spotlight and is now on the radar of many industries.

Not only is inappropriate behavior in the form of sexual harassment on the radar, but I predict that the next wave of change will involve general harassment and hostile work environments.

Ladies and gentlemen, the time to take a stand is now. As leaders within the hospitality industry, it is our duty to ensure that we create, promote, and foster a safe working environment that is fair, equitable, and free of harassment of all kinds for all people. We have all said regrettable or off-color things, but we have to draw a line as there comes a time when enough is enough and the industry itself can be at stake.

As a human resource professional in the hospitality industry for more than 15 years, I have heard, seen, and addressed many of these types of issues. I want to leave you with some actionable tips and ideas to ensure:

  1. You implement best practices and policies to prevent a hostile work environment and harassment.

  2. You maintain a working environment that promotes fair, positive, and equal treatment.

Let’s begin.

The first thing you need to do is train a critical eye on your own organization. Ask yourself the following questions:

  1. Do you promote an environment that advocates for fair, positive, and equal treatment of all employees? This truly stats from the top down and relies heavily on upper management, both General Managers and Executive Chefs alike setting the tone and expectations.

  2. Are your policies clear and concise? Establishing an anti-harassment policy doesn’t guarantee a complete absence of harassment complaints. However, implementing an effective policy and procedure, coupled with anti-harassment training for all staff, will assist in preventing harassment and support individuals who are being harassed to come forward and ensure problems are addressed quickly and effectively.

  3. Are your policies clearly communicated to all employees? Make sure you dedicate a section to harassment in your company handbook, and consider posting important policies in your establishment where your team will see them.

  4. Do you offer annual anti-harassment training with follow-up refreshers and re-training? With everything happening in the news, there is no time like the present. These should be as regular as your alcohol awareness classes that take place on a yearly basis in some states.

  5. Do you closely monitor questionable behavior? Don’t turn a blind eye to inappropriate comments, pictures, or conversations that can be construed as inappropriate in a workplace setting. Ignoring once sets a precedent that can lead to more issue in the future. 

  6. Do your employees have a process for addressing harassment and other workplace issues in a confidential, sensitive manner? It is of the utmost importance that they are provided with the means to do so through a well-constructed and well-implemented plan and process. This may stop inappropriate conduct before it escalates and ultimately creates more problems for individual employees or the company as a whole.

  7. When a complaint is filed with HR or management, do you do your due diligence and take steps to resolve it? My advice is to take everything seriously - until you take the time to investigate, you won’t know the truth. Good HR practices can end up saving your restaurant and/or hotel in the future and help prevent future lawsuits.

  8. Do you set expectations before all employee functions? You are responsible for clearly communicating that people must maintain respect and decorum. This is incredibly important to reversing the culture that has taken hold in the industry and ensure a new one is born.  

  9. When an issue arises, do you seek legal advice? It is highly recommended that you do so, especially if the situation involves violence. HR and legal services can work in tandem to address the situation and resolve the matter quickly while protecting the business.

  10. Do you lead by example? If you want to ensure your environment lives and breathes respect, make sure you are the beacon leading the charge.

A hostile work environment is not conducive to productivity, creativity, or career longevity. Therefore, because of the legal and moral predicaments that arise when harassment or assault happens in the workplace, it makes good business sense to adhere to strict protocols.

Yes, harassment in the workplace can affect your bottom line. The emotional and mental toll it can take on your employees can be quite costly. Each year, millions of dollars are lost due to absences, decreased productivity, high employee turnover, low morale, and legal costs - all stemming from harassment. A happy, healthy employee means more profit towards the bottom line and healthier industry as a whole.

At the end of the day, it is your responsibility to make sure you do right by your employees by fostering an environment free of harassment and ensure you don’t have a “touchy” kitchen.


About the Author

Cleo Clarke is the Vice President of Human Resources Strategy & Development at Harri. Clarke is a senior HR professional and has held an executive role in the hospitality industry for more than 15 years.