Recruitment Privacy Notice
Last updated: March 2021
What is the purpose of this document?
Seven Investment Management, 3rd Floor, 55 Bishopsgate, Cornhill, London (“7IM”) is a “data controller”. This means that we are responsible for deciding how we hold and use any information which can be used to identify you (“Personal Data”). You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, consultant or contractor). It makes you aware of how and why your Personal Data will be used, namely for the purposes of the recruitment exercise to assess your suitability for the role, and how long it will usually be retained for.
It provides you with certain information that must be provided under the Data Protection Act 2018 which incorporates the UK General Data Protection Regulation (GDPR) and any legislation implemented in connection with the GDPR. This includes any replacement legislation coming into effect in the UK from time to time (“Data Protection Legislation”).
Data protection principles
We will comply with Data Protection Legislation 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; and
- 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 Data about you:
- The information you have provided to us in your curriculum vitae, application form and any covering letter accompanying your application;
- Information confirming your eligibility to work in the UK; and
- Any information you provide to us during an interview relevant to assessing your suitability for the role;
The lawful basis we rely on for processing personal data as part of your application is processing necessary to perform a contract or to take steps at your request, before entering a contract.
The lawful basis we rely on for confirming your eligibility to work in the UK is to comply with our legal obligation.
Sensitive personal data
7IM may also collect, store and use the following types of more sensitive Personal Data:
- Information about your race or ethnicity, religious beliefs or sexual orientation for the purposes of equal opportunities monitoring. Providing us with this information is not mandatory. If you don’t provide it, it won’t affect your application; or
- Information about your health, including any medical condition, health and sickness records for the purposes of making reasonable adjustments within the proposed role and/or during the interview. If you provide us with any information about reasonable adjustments you require under the Equality Act 2010 the lawful basis we rely on for processing this information is to comply with our legal obligations under the Act and relates to our obligations in employment.
How we will use personal data about you
We will use the Personal Data 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 and to help us keep track of applications that were made directly by you and those that were made via a recruitment agency.
- comply with legal or regulatory requirements.
- decide whether to enter into a contract of employment with you.
- add you to our talent pool to inform you about future vacancies.
- defend or institute a legal claim.
How we use your sensitive personal data
We will use your sensitive Personal Data in the following ways:
- to provide appropriate adjustments during the recruitment process, for example adjustments related to access requirements
- to ensure meaningful equal opportunity monitoring and reporting. The data used in the reports will be anonymised.
Hiring Managers do not have access to your sensitive Personal Data during the recruitment process. Only the Recruitment Team have access to this information.
Having received your CV and covering letter 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. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and carry out a criminal record check and other necessary checks, where required before confirming your appointment.
We are required to perform all of these processing actions in order to engage in the employment contract with you.
Personal data collected upon offer of employment
For certain positions, it is necessary to carry out credit and criminal records checks once an offer is accepted to ensure that individuals are permitted to undertake the role in question
If your application is successful and you are offered a position with 7IM, we may also require information relating to your stated referees and/or references and where applicable current or previous directorships held.
Once you progress to completing the information required for all new staff members at 7IM, you will be issued with a 7IM Staff Member Privacy Notice, which details how and why we process your personal data as a staff member of 7IM.
Why we collect information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the position (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- We are legally required by the Financial Conduct Authority (FCA) to carry out criminal record checks for those carrying out a role with 7IM;
- Where the nature of the role undertaken and/or any convictions identified may require reporting to the FCA under our regulatory requirements (and any subsequent ‘fit and proper’ tests mandated by the FCA); and
- Where the role requires a high degree of trust and integrity since it involves operating in an environment with potential access to high value client money, we would ask you to seek a basic disclosure of your criminal records history.
We have in place an Appropriate Policy Document and safeguards which we are required by law to maintain when processing such data.
How is your personal data collected?
We collect Personal Data about applicants from the following sources:
- You, the applicant.
- Recruitment agencies, from which we collect the following categories of data: contact information, qualification history, employment history, education details.
- Vero Screening background check provider, from which we collect the following categories of data: Confirmation of ID, confirmation of address, qualification and employment history data.
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees, from whom we collect the following categories of data: Employment history, role, duration and reference data.
If you fail to provide Personal Data
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 the role you applied for and you fail to provide us with relevant details, we will not be able to take your application further.
We use an automated process to decide whether or not to review your application. This process uses responses you provide to some preliminary questions, to determine whether or not you have a right to work in the U.K.. Depending upon the response received, your application may be progressed for review by one of our hiring managers. This information is important because it is an offence to knowingly employ someone who does not have a right to work in the UK.
If you wish to challenge the decision made please contact us by emailing firstname.lastname@example.org.
We use data processors who are third parties who provide elements of services for us. We have data processing agreements in place with our data processors. This means that they cannot do anything with your Personal Data unless we have instructed them to do it.
We will only share your Personal Data with the following third party service providers for the purposes of processing your application: Background screening companies and the applicant tracking system provider.
7IM is part of the 7IM Holdings group of companies (the 7IM Group). Any personal information that you share with 7IM or that is received from third parties such as recruitment agencies and that is added to the talent pool will be shared with and processed by PWM, another member of the 7IM Group for recruitment purposes.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data 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.
We may also share your Personal Data with the following third parties who are not our data processors:
- Your previous employers for reference purposes
- Law enforcement agencies
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your Personal Data 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.
7IM do not collect or store any of your personal details on the recruitment page of our website, however when you click on the link to apply for a job then you will be transferred to our third-party Applicant Tracking System provider, Eploy who store the data on our behalf.
How long is your information kept?
For unsuccessful applicants, we will retain your Personal Data for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role. We retain your Personal Data for that period so that we can show, in the event of a legal claim, that we have not discriminated against applicants on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, if you are not in the process of applying for another position, your Personal Data will be deleted in accordance with our data retention policy, unless you give your consent for us to store your data for a further 12 months. You have a right to withdraw your consent at any time.
We will also your Personal Data for this period for purpose of adding you to our talent pool, on the basis that a further opportunity may arise in future and we may wish to consider you for that. We also keep a log of all applications received for record purposes to keep track of applications received directly or via recruitment agencies.
All of your Personal Data will be held within the U.K.. Our data processor, Eploy, has been instructed not to transfer or store your Personal Data outside the U.K.. Eploy hosts your Personal Data on Azure in their U.K. datacentres.
Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data 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 Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data 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 if we process your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your personal data, request that we transfer a copy of your Personal Data to another party, or withdraw your consent, please contact our Recruitment Team by emailing email@example.com.
If you have any questions about this privacy notice or how we handle your Personal Data, please contact the Recruitment Team at firstname.lastname@example.org.
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.
Changes to this privacy notice
We may alter this Privacy Notice to ensure that it always accurately reflects the way 7IM collects, uses and safeguards the Personal Data of job applicants and to reflect changes to law and best practice. The updated Privacy Notice can be viewed on the careers page of our website. Changes posted on this page will apply as soon as they are posted.