CANDIDATE FAIR PROCESSING NOTICE
1. About this Notice
St. James's Place is committed to protecting the privacy of its job applicants.
This Notice sets out important information about how St. James's Place collects and uses personal data (referred to as "personal information" in this Notice" as part of its recruitment processes. You should read this Notice carefully and raise any questions you may have with the Data Protection Officer.
This Notice is issued on behalf of St. James's Place Plc and its associated companies. In connection with your potential employment, the relevant data controller will be your prospective employer within the St. James's Place group of companies. A full list of these companies appears at annex 1 to this Notice. St. James's Place has appointed a dedicated Data Protection Officer to deal with any queries in relation to data processing and the relevant contact details are provided below.
2. Our processing of your personal information
Personal data means information which identifies you and relates to you as an individual. As your prospective employer, St. James's Place will collect, use and store your personal information for a number of purposes in connection with its consideration of you as a candidate for employment.
In accordance with its obligations St. James's Place will ensure your personal information is:
- processed fairly and lawfully
- obtained and processed only for specified and lawful purposes
- adequate, relevant and not excessive
- accurate and kept up to date
- held securely and for no longer than is necessary
- not transferred to a country outside of the EU unless there is an adequate level of protection in place
St. James's Place will review the nature of information being collected and held from time to time to ensure that these principles are being followed.
2.1 What personal information do we collect?
We have set out below the main categories of candidate personal information which we process in connection with our recruiting activities on a day to day basis:
- personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address)
- work history and other relevant experience including information contained in CV, cover letter or job application form
- education information including degrees awarded, transcripts and other information provided in support of the job application
- remuneration history
- information collected during phone screenings and interviews
- details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits
- reference information and information received from background checks (where applicable) including information provided by third parties
- information related to previous applications to us or previous employment history with us
- documents evidencing your right to work (including information about your immigration status where relevant)
- date of birth
- information gathered through our monitoring of our IT systems, building access records and CCTV recording in relation to your communications with us and attendance at our premises
- personal information which you otherwise voluntarily provide during the course of the recruitment process
The majority of the personal information to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.
The list set out above is not exhaustive, and there may be other personal information which St. James's Place collects, stores and uses in the context of the application and recruitment process. St. James's Place will update this Notice from time to time to reflect any notable changes in the categories of personal information which it processes.
The majority of the personal information which we process will be collected directly from you. However, your personal information may also be provided to us by third parties, such as recruitment agencies, former employers, official bodies (such as regulators or the Disclosure and Barring Service) and/or medical professionals.
2.2 What background checking do we undertake?
As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:
- former employers, in order to verify your previous employment history
- universities and/or other establishments for higher education that you attended, in order to verify your education history
- for specific roles we will undertake electronic ID checks, sanctions and politically exposed persons checks via a third-party agency
We will also gather data from publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites
We will only conduct background checking in relation to successful candidates that have accepted a conditional offer of employment with us, and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
2.3 What do we use your personal information for?
St. James's Place uses your personal information for a variety of purposes to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal information is processed:
- to identify and evaluate job applicants, including assessing skills, qualifications and experience
- verifying candidate information and carrying out employment, background and reference checks, where applicable, and in order to prevent fraud
- communicating with you about the recruitment process and your application
- to comply with our legal, regulatory, or other corporate governance requirements
In addition to using your personal information to consider you for the role you applied for, we will retain and process your personal information to inform you about, and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your recruitment contact.
Again, this list is not exhaustive and St. James's Place may undertake additional processing of personal information in line with the purposes set out above. St. James's Place will update this Notice from time to time to reflect any notable changes in the purposes for which its processes your personal information.
2.4 When will we share candidate personal information?
St. James's Place will share candidate personal information with other parties only in limited circumstances where this is necessary for the purposes of entering into an employment contract, to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests as follows:
- recruitment agencies
- background vetting specialists
- occupational health providers and other medical professionals
- HMRC and/or any other applicable government body
- accountants, lawyers and other professional advisers
- the Financial Conduct Authority and/or the Prudential Regulatory Authority and/or any other applicable regulatory body
- specialists undertaking psychometric & personality tests
Wherever possible the personal information is shared under the terms of a written agreement between St. James's Place and the third party which includes appropriate security measures to protect the personal information in line with this Notice and our obligations. The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.
3. What special category (sensitive) data do we process?
Certain categories of data are considered "special categories of personal information" and are subject to additional safeguards. St. James's Place limits the special categories of personal information which it processes as follows:
- Health Information
We may process information about a candidate's physical or mental health in the course of the recruitment process. In particular:
- we will process information about an individual candidate's physical or mental health to comply with our obligations to make reasonable adjustments for disabled employees as part of the recruitment process;
- as part of our pre-employment screening, successful candidates are asked to complete a medical questionnaire administered by Health Assured Ltd in order that we can take account of any medical issues relating to a new employee, including our obligation to make reasonable adjustments in the workplace. Health Assured Ltd will only share information from this questionnaire with us with your express consent.
We will always treat information about health as confidential and it will only be shared internally where there is a specific and valid purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration, or disclosure.
If a candidate is successful, any health information processed as part of the recruitment process that is relevant to St. James's Place's compliance with its obligations in connection with employment will be retained and processed in accordance with the Employee Privacy Notice.
If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal information within months of their rejection.
4. How long do we keep personal information for?
St. James's Place's policy is to retain personal information only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal information so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
For unsuccessful candidates:
- We will typically retain personal information collected during the recruitment process for a maximum period of 6 months from the end of the process subject to any exceptional circumstances and/or to comply with particular laws or regulations.
If you are offered and accept employment with us, some of the personal information we collected during the application and recruitment process will become part of your employment record and we may use it in connection with your employment in accordance with the Employee Privacy Notice.The remaining data will be stored for a period of 6 months then deleted
5. Your rights
St. James's Place will always seek to process your personal information in accordance with its obligations and your rights.
You will not be subject to decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal information, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal information. You also have the right to request the transfer of your personal information to another party in a commonly used format. If you have any questions about these rights, please contact the Data Protection Officer using the details provided.
You have a separate right of access to your personal information processed by St. James's Place. You may be asked for information to confirm your identity and/or to assist St. James's Place to locate the data you are seeking as part of St. James's Place's response to your request. If you wish to exercise your right of access you should set out your request in writing to the Data Protection Officer using the details provided.
Finally, you have the right to raise any concerns about how your personal information is being processed with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or firstname.lastname@example.org.
6. Google Analytics
In addition, we use Google's remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James's Place employees comply with legal obligations and St. James's Place policies and procedures (including our customer relations practices).
As you may be aware, no data transmission over the internet can be entirely secure. As a result, while we will always use reasonable endeavours to protect your Personal Information, we cannot guarantee the security of your Personal Information and the use of our Site (including the e-mail facilities) is at your own risk
11. Contacting us
If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our Data Protection Officer by emailing email@example.com or by writing to Data Protection Officer, St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom
12. Updates to this Notice
From time to time we may need to make changes to this Notice, for example, as the result of changes to law, technologies, or other developments.
This Notice was last updated on 4th May 2018