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Like most businesses, we hold and process a wide range of information, and some of this relates to individuals who are applying to work for us, whether as a permanent or temporary employee, contractor, consultant, agent or intern.
This Recruitment Privacy Notice explains the type of information we process during the recruitment phase, why we are processing it, and how that processing may affect you. We have a separate Workplace Privacy Notice that applies to all our current employees.
In ‘Annex 1 - Supplementary Information’, we explain what we mean by ‘personal data’, ‘processing’, ‘special categories of personal data’ and other terms used in this Recruitment Privacy Notice.
In brief, this Recruitment Privacy Notice explains:
We process data for the purposes of our business including recruitment, management, administrative, employment and legal purposes. Annex 1 - Supplementary Information provides more specific information on these purposes, on the type of data that may be processed and on the grounds on which we process data.
When you apply to work for us the initial data about you that we process is likely to come from you: for example, contact details, bank details and information on your immigration status and whether you can lawfully work for us.
We will, where necessary, and as set out in this Recruitment Privacy Notice, require references and information from you to carry out background checks on you. If you do not provide us with the necessary information, or information that you are required to do by statute or contract, we may decide not to employ you. If you have concerns about this, in a particular context, you should speak to your recruiter or our HR department.
We may also receive data from third party recruiters, agents and similar organisations as a part of the recruitment process and from your referees that provide us with references.
We do not keep your personal data for any longer than is necessary for our purposes. In general, if you become employed by us, we will keep your personal data for the duration of your employment and for a reasonable period afterwards, as is more particularly set out in Appendix 12 of our Records Management Policy in respect of each of the relevant data categories. If you are unsuccessful in gaining employment with us, we will keep your personal data for no longer than 6 months after informing you that you were unsuccessful. In considering how long to keep your data, we will take into account its relevance to our business and your potential employment, either as a record or in the event of a legal claim.
In processing your personal data, Peel Hunt LLP acts as a data controller.
If you have any questions about this Recruitment Privacy Notice, or want to exercise your rights set out in this Recruitment Privacy Notice, please contact us by:
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the Information Commissioner’s Office (ICO). You can contact the ICO using the following website https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
This Recruitment Privacy Notice does not form part of any contract of employment you might enter into with us and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this Recruitment Privacy Notice is intended to create an employment relationship between Peel Hunt LLP and any non-employee providing services to us.
‘Personal data’ means any information relating to you as a living person (the ‘data subject’) which can be used to identify you – directly or indirectly – by reference to an identifier such as a name, an identification number, location, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. It not only includes facts about you, but also intentions and opinions about you.
‘Processing’ means any operation which is performed on personal data, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination or erasure or destruction of personal data.
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be ‘special categories of personal data’.
References in this Recruitment Privacy Notice to employment, work (and similar expressions) include any arrangement we may have under which an individual provides us with work or services (including but not limited to employees, previous members of Peel Hunt LLP, temporary workers, contractors, consultants, advisors and interns). By way of example, when we refer to an ‘employment contract’, that is taken to include a contract under which you provide us with services; when we refer to ending your employment, that includes terminating a contract for services. We use the word ‘you’ to refer to anyone within the scope of this Recruitment Privacy Notice.
Under data protection law, there are various grounds on which we can rely, when processing your personal data. In some contexts, more than one basis applies. We have summarised these grounds as Contract, Legal Obligation, Employment purposes, Legitimate Interests and Consent, and we outline what those terms mean in the following table.
Grounds for processing
Processing necessary for the performance of a contract with you, or to take steps at your request to enter a contract.
This covers carrying out our contractual duties and exercising our contractual rights such as those set out in our legal terms of employment with you.
Processing necessary to comply with our legal obligations.
Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Processing necessary for the purposes of initiating employment.
This includes activities concerned with the initiation of employment or membership, or any other arrangement that we may have under which an individual provides us with work or services.
Processing necessary for our, or a third party’s, legitimate interests.
We may process your personal information for our and others’ legitimate business interests whilst applying appropriate safeguards that protect your privacy.
Your data will not be processed on this basis if our, or a third party’s, interests are overridden by your own interests, rights and freedoms.
You have given specific consent to processing of your data.
In general, processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things, such as requesting a reference or obtaining criminal record checks, and we rely on your consent to do so.
We may process special categories of personal data about you (for example, about your gender or for the purposes of diversity monitoring), but only when one or more of the following grounds for processing such personal data applies:
This Recruitment Privacy Notice outlines the purposes for which we process your personal data. More specific information on these, examples of the data, and the grounds on which we process data, are outlined in the table below.
The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention data relating to criminal offences, if we were to find out that someone applying to work for us was suspected of committing a criminal offence, we might process that information if relevant for our purposes. We also require basic criminal background checks for all roles, and standard checks for Senior Management Functions.
Examples of personal data that may be processed
Recruitment in relation to any job for which you apply and/or any job we think you might be suitable for in the future
Standard data related to your identity (e.g. your name, address, email address, identity verification documentation, telephone numbers, place of birth, nationality, contact details, professional experience and education (including university degrees, academic records, professional licences, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information and other remuneration), language skills, and any other personal data that you present us with, as part of your application, related to the fulfilment of the role.
Information concerning your application, and our assessment of it, your references, any checks we may make to verify information provided, background checks, and any information connected with your right to work.
If necessary, we will also process information concerning your health, any disability, and in connection with any adjustments to working arrangements.
Legitimate interest: to carry out informed recruitment decisions and evidence considered capability, conduct and F&P for regulatory purposes
Administering our recruitment process
Evaluating your experience and qualifications against the requirements of the position you are applying for (or any future job for which we think you are suitable).
Administering our online careers administration portal.
Communicating with you in respect of any offer of employment, membership or other work experience that we choose to make, and providing you with information about our new joiner on-boarding process.
Legitimate interest: to carry out informed recruitment decisions and evidence considered capability, conduct and F&P for regulatory purposes.
Entering into a contract with you (if you are made an offer by us)
Information on your terms of employment, from time to time, including your hours and working patterns, and your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes.
to have an accurate record of your employment contract for its performance and variation.
Conducting pre-employment screening to assess your suitability for employment and to comply with regulatory obligations
Information such as criminal records, credit checks, county court judgement checks, adverse media checks, education records, previous employment records and references (regulated and non), legal admissions, directory checks, bankruptcy filings, professional qualifications, and any other relevant background checks.
Legal & regulatory obligations
Legitimate interest: to carry out informed recruitment decisions and evidence conduct and F&P for regulatory purposes.
Contacting you or others on your behalf
Your address and telephone number, emergency contact information, and information on your next of kin.
Legitimate interest: the ability to contact you, or others on your behalf in an emergency.
Payroll administration (if you are made an offer by us)
Information on your address, date of birth, bank account details, pension contributions, tax and national or social insurance numbers or codes and payments, unique taxpayer reference number or other government issued identifier.
Legitimate interest: the ability to carry out payroll, general HR and business administration in an efficient manner, and to plan around your absence where necessary.
Financial planning and budgeting
Information such as your proposed salary and other remuneration, if applicable.
Legitimate interest: the ability to carry out effective financial planning and budgeting for our business, analysis and benchmarking
Providing information to third parties in connection with transactions that we contemplate or carry out
Information on any offer made to you and your proposed contract and other employment or membership data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer.
Legitimate interests: requirement of due diligence process to ensure all necessary information is duly provided so that an informed decision can be made.
Monitoring of diversity and equal opportunities
Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability, age and socio-economic status as part of diversity monitoring initiatives. Such data may be aggregated and used for equality of opportunity monitoring purposes.
Please note, we may share aggregated and anonymised diversity statistics with regulators, if formally required or requested.
Legitimate interest: to ensure that we have an equal and diverse workforce: processing is necessary for reasons of substantial public interest.
Disputes and legal proceedings
Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.
Legitimate interest: the ability to investigate, establish, commence, respond to and defend against legal claims.
Please note that if you accept an offer from us we may process further information about you. We will provide you with our full Workplace Privacy Notice as part of the new joiner on-boarding process.
Where necessary, and as set out this Recruitment Privacy Notice, your personal data will be disclosed to HR and Compliance and prospective line-managers, for employment, administrative and management purposes as mentioned in this Recruitment Privacy Notice. We will also disclose this to other members of the Peel Hunt group, where necessary for decision making regarding your application – this will depend on the type of role you are applying for.
We will only disclose your personal data outside Peel Hunt if disclosure is consistent with one of the grounds for processing on which we rely, and doing so is lawful and fair to you.
We will disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party; but we will not do this if these interests are over-ridden by your interests and rights, in particular to privacy. Where necessary, we will also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.
Specific circumstances in which your personal data may be disclosed include (but are not limited to):
We try to be as open as we reasonably can about personal data that we process. If you would like specific or further information, please ask our HR department.
You also have a legal right to make a ‘subject access request’. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
As well as your subject access rights, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example, your address or bank details), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the grounds for processing is Consent or Contract.
If we have relied on consent as a grounds for processing, you may withdraw consent at any time – although, should you do so, this will not affect the lawfulness of what we have done before you withdrew your consent.
If you have complaints relating to our processing of your personal data, you should raise these with HR in the first instance. You may also raise complaints with your statutory regulator. For contact and other details please speak to our HR department at email@example.com
Please note: References throughout this Recruitment Privacy Notice to employees, employment, employment contracts, work, or similar expressions, include any arrangement that we may have under which an individual provides us with work or services. This includes, but is not limited to: employees, temporary workers, contractors, consultants, agents, advisors and interns.
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