PURPOSE
Greensill Capital Management Company (UK) Limited (Greensill) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
You are being asked to review this privacy notice as you are applying to work with us (whether as an employee, worker or contractor). It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and UK Data Protection Act 2018 (DPA 2018).
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
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:
Where included in your application documentation, we may also collect, store and use the following types of more sensitive personal information:
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
In line with article 6(1)(b) of the GDPR, we need to process your personal information to take steps and decide whether to enter into a contract of employment or contract for services with you at your request.
We will process your personal information to decide whether you meet the basic requirements to be shortlisted for the role you applied for. 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 or work. If we decide to offer you the role, we will then request you complete pre-employment screening and we may carry out a criminal record and/or credit reference check 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
Where provided, we will use your particularly sensitive personal information in the following ways:
We process sensitive personal information you provide as part of the application process in line with article 9(2)(b) of the GDPR which relates to our obligations in employment and the safeguarding of your fundamental rights. In addition, we rely on the processing condition at Schedule 1 part 1(1) of the DPA 2018 which also relates to processing for employment purposes.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We will collect information about your criminal convictions history if we decide to offer you a job. We are entitled 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:
AUTOMATED DECISION-MAKING
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
DATA SHARING
Why might you share my personal information with third parties?
We will only share your personal information with the following 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 information for their own purposes. We only permit them to process your personal information 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?
If your application is unsuccessful, we will retain your personal information for a period of 2 years after we have communicated to you our decision about whether to appoint you for the role or to provide the service. 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. After this period, we will securely destroy your personal information.
If your application is successful, an employee file will be opened for you and your personal information will be retained in line with retention schedule for employee records.
If we wish to retain your personal information on file, 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:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact the Privacy Officer using the contact information below.
CONTACT DETAILS
We have appointed a Data Protection Officer to oversee compliance with data protection laws. If you have any questions about this privacy notice or how we handle your personal information, please contact the Privacy Officer at data.protection@greensill.com.
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.