Candidate Privacy Notice

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:

  • 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 including name, title, address, telephone number, personal email address, date of birth, employment history, qualifications, referees and references, nationality, right to work information, professional memberships, education, experience, video recordings and photographs and answers to questions relevant to the role.
  • Any information you provide to us during an interview.
  • Information relating to your credit history.

Where included in your application documentation, we may also collect, store and use the following types of more sensitive personal information:

  • Information about your health, including any medical condition, health and sickness records.
  • Information about your gender, race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • 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.
  • Third party recruitment agencies through which you submitted your application.
  • Our recruitment portal.
  • Our website.
  • Third party job boards and job portals such as LinkedIn through which you submitted your application, or we contacted you about positions at Greensill.
  • Our pre-employment screening provider, we will however ask you for consent prior to conducting these checks, a provider of credit reference checks, criminal records checks, and in some territories qualifications checks.

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 or work to be done.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes in line with our retention schedule.
  • Comply with legal or regulatory requirements.
  • Carry out background and reference checks, where applicable.

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 will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process; and
  • We will use information about your gender, 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 in accordance with any governing legislation the Equality Act 2010.

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:

  • where there is a ‘regulatory requirement’ and this includes ‘requirements forming part of general accepted principles of good practice’ in relation to the relevant area, as well as those set out in law
  • Where the role requires a high degree of trust and integrity, we would like you to seek a basic disclosure of your criminal records history at our cost through our designated provider.
  • We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

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:

  • Our pre-employment screening provider

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:

  • 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. In certain circumstances this right 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 our 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. In certain circumstances, 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 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.