What is the purpose of this document?
You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) and the UK General Data Protection Regulation (“GDPR”).
Data protection principles
We will comply with data protection law and principles, which means that your data will 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.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
The information you have provided to us in your curriculum vitae and covering letter.
The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications.
Information regarding your current level of remuneration, salary expectations and benefit entitlements.
Information regarding your entitlement to work in the UK.
Any information you provide to us during an interview or other assessments (for example our trainee assessment centres).
Information regarding any reasonable adjustments we need to make to the recruitment process due to any disabilities.
Any information you provide in the FCA Form A.
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.
Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
You, the candidate.
Recruitment agencies, from which we collect the following categories of data: curriculum vitae, current remuneration, salary expectations, DOB, benefit entitlements, notice period requirements, contact details (including phone number, email address and home address) and current location.
Background check providers, from which we collect the following categories of data: CRB check detailing any unspent criminal convictions, right to work in the UK via Credas, DVLA check detailing driving licences and information regarding endorsements (via an online platform DAVIS) and occupational health information regarding any reasonable adjustments required for disabilities.
Credit reference agencies, from which we collect the following categories of data: electoral register, court judgements, bankruptcies, insolvencies and credit agreements.
Your named referees, from whom we collect the following categories of data: name, address, employment details or character/education information.
How we will use information about you
We will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the role.
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.
We have a legitimate business interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your CV and/or application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview/assessment centre. If we decide to call you for an interview or invite you to our assessment centre, we will use the information you provide to us at the interview and/or on the assessment day to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
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.
As mentioned above, we may process information about your right to work in the UK, by way of a third-party software tool known as ‘Credas’, as may be changed by us from time to time. This may be considered profiling under data protection legislation, of which any profiling undertaken by us will be subject to our compliance with all applicable laws (and for the avoidance of doubt, this will not constitute automated decision-making due to the human intervention element).
Information about criminal convictions
We envisage that we will process information about criminal convictions by way of a third-party software tool known as ‘U Check’, as may be changed by us from time to time. This may be considered profiling under data protection legislation, of which any profiling undertaken by us will be subject to our compliance with all applicable laws (and for the avoidance of doubt, this will not constitute automated decision-making due to the human intervention element).
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process, undertake a CRB background check or we may be notified of such information directly by you in the course of you working for us.
Automated decision-making
During our recruitment process, we may use automated decision-making to assess your application for the job role and determine your suitability as a candidate. This automated decision-making may include (without limitation) using certain tools and software to measure or otherwise test your aptitude for mathematics, determine your right to work in the UK or other skills required for the role. Given the volume of applications that we have for roles, automated decision-making is used in the recruitment process to ensure that we can efficiently and swiftly process applications, to avoid delay and reduce the resource required during the process.
In certain cases, if you fail to meet a prescribed score/requirement (as determined by the automated tools and software), you will not progress any further in the recruitment process and will therefore no longer be considered for the job role. We will not always review the decision produced through automated methods and as such, there may not be any human involvement in the automated decision-making process.
However, we do not use automated decision-making in circumstances where such decision-making would have legal or similarly significant effects on you.
We have tested any tools and software used for automated decision-making to ensure that they are fair, effective and unbiased
Data sharing
Why might you share my personal information with third parties?
We will only share your personal information with third parties for the purposes of processing your application. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow 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 and in accordance with our instructions.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will retain your personal information for a period of 3 years after we have communicated to you our decision about whether to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. It also enables us to contact you for consideration of any future appropriate employment opportunities. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file for a further period, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Rights of access, correction, erasure, and restriction
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.
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 our HR team, in writing.
Data compliance team
We have appointed a data compliance team to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our data compliance team, whose details are available in the Privacy Policy on our website. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
May 2025