Candidate Privacy Notice
SFM UK Management LLP and its associated entities (“SFM”, “we” or “us”) are each a data controller for the purposes of data protection law. As part of our recruitment activities, we collect and process personal data (“personal information”) relating to job applicants. This Candidate Privacy Notice (“Privacy Notice”) sets out what personal information we collect when you apply for a role with us, why we collect it and how it is processed. Processing includes all activities relating to your personal information and in addition to collection means storage, handling, sharing, accessing, using, transferring, and disposing of it.
What personal information do we collect and process?
We collect personal information in a number of ways. This may be through you providing it to us verbally or in writing, in emails, via Greenhouse, our cloud services recruiting system provider, in application forms or CVs or during our interactions, or from third parties such as recruitment agencies, referees or colleague referrals. We may also collect personal information from sources where you have made it publicly available such as LinkedIn or other social media networks.
The non-exhaustive list below contains examples of the types of personal information we process:
- Personal and contact details such as your name, address, email address, phone number and date and place of birth
- Education and work history, professional qualifications, experience, and skills
- Remuneration and benefits entitlements information
- Nationality, visa, right to work and identity information (e.g. passport, driving licence, number)
- Results of pre-employment screening (e.g. prior employment, credit history, criminal record checks where permitted under local law and where relevant to the role)
- Assessment results and information from interviews
- Information provided by third parties such as a recruitment agency or referee, or publicly available information
Why do we process personal information?
We process your personal information in connection with recruitment for one or more purposes and where we have a legal basis to do so including those listed below:
- We have a legitimate interest in managing the recruitment process, assessing and confirming a candidate’s suitability for employment, making hiring decisions and communicating with candidates.
- To ensure we are complying with our regulatory or legal obligations, such as in connection with eligibility to work, or because of the requirements of our Regulators.
- It may be necessary for us to process your personal information for entry into or performance of the employment contract.
We also process special categories of personal information:
We also process special categories of personal information such as information relating to your racial or ethnic origin, religious beliefs, sexual orientation, or physical or mental health. We do not process special categories except where we are required or permitted to do so by applicable law, or we have in accordance with legal requirements, obtained your consent. Examples of when we may process special categories of personal information include the following:
- To enable us to comply with employment law obligations such as making reasonable adjustments for a candidate who is disabled.
- For equal opportunities monitoring purposes to help ensure we conduct recruitment processes which comply with discrimination laws, or for the substantial public interest reason of maintaining and promoting equality of opportunity and diversity, equity and inclusion.
- We may also have to use special category personal information to conduct criminal background checks. This special category of personal information will only be processed where permitted or necessary in accordance with local laws, or where you have provided explicit consent where this is required.
Who do we share your personal information with?
Your personal information will be shared with our recruiting system provider, Greenhouse Software Inc and internally within SFM with members of the HR team and managers involved in the recruitment process business areas with a vacancy.
We may also share it with third parties as needed, in order to seek references, to conduct background checks, or with a regulator or other authority, or third-party suppliers such as benefits providers. This may be to comply with our legal obligations or perform our contractual obligations in relation to you (for example, to ensure you are set up on our systems from your first day of work.)
How do we protect your personal information?
Our systems are protected to ensure that your personal information is not lost, accidentally destroyed, misused, nor accessed by anyone outside the proper performance of their duties. To the extent that your data is processed by a third party, we make sure that they promise to give your data equivalent protection. If your application is unsuccessful, we will hold your personal information on file for 18 months, after which it will be deleted or destroyed unless you want us to retain it for longer to be considered for other opportunities, or there are particular reasons or requirements to retain it for longer. This could be where we have to retain a record of it in relation to legal or regulatory obligations, or in the defence of a legal claim. If you become employed by us, personal information gathered during the recruitment process will be retained and will be subject to our separate Employee Data Privacy Statement.
As an international organisation, personnel authorised by us may access your personal information in any country in which SFM operates, including the United States of America, and which do not have equivalent privacy laws to those in the UK or the EU. Regardless of where your personal information is transferred, we shall ensure that it is secure and subject to appropriate safeguards.
Your rights
You have the following rights under data protection law. You can:
- Access and obtain a copy of your personal information on request
- Require us to correct inaccurate or incomplete data
- Request that we delete your personal information or stop processing it, for example where you feel we no longer need to process it for the purpose for which it was provided, or where consent was required for processing and you wish to withdraw it
- Object to processing where we are relying on a legitimate interest as the ground for processing
- Request that we restrict the processing of your personal information if for example you wish us to suspend processing in order to establish its accuracy or the reason for us processing it
- Request that we transfer your data to another party.
If you would like to exercise any of these rights or have any questions about this Privacy Notice please contact Rebecca McCourt at Rebecca.mccourt@soros.com or on +44 207 758 4859. You may also make a complaint to the authority responsible for upholding data protection rights, if you feel you have grounds to do so. In the UK this is the Information Commissioner’s Office (www.ico.org.uk or at 0303 123 1113).