Privacy Notice for Applicants (including work experience and work placement students)

ABOUT THIS PRIVACY NOTICE

This section explains how we are committed to protecting the privacy and security of your personal data. It also explains how compliance with this Privacy Notice will be monitored.

HOW WILL WE USE YOUR PERSONAL DATA?

This section explains how we will collect, store and use personal data that you provide to us. This is to enable us to carry out our activities and obligations as your employer or prospective employee.

WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

This section explains which of our employees will have access to your personal data. It also explains the reason for our employees accessing your personal data.

HOW WE PROTECT YOUR DATA

This section explains how we protect your personal data.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

This section explains the length of time that we will retain your personal data. It also explains why we would hold your personal data for such time periods.

TELLING US ABOUT CHANGES

This section explains that we need to know about any changes to your personal data and tells you how to go about informing us of such changes.

WHAT ARE YOUR RIGHTS?

This section explains that you have rights in relation to your personal data. It also explains what these rights are and how you can go about exercising them.

WHO CAN YOU ASK FOR MORE INFORMATION?

This section provides you with contact information should you have any questions or concerns about the way we handle your personal data. It also explains how you can contact the data protection regulator should you be unsatisfied with our response to your data protection.

1. INTRODUCTION

1.1 Capital Generation Partners Services Limited (referred to as “we” in this agreement) is committed to protecting the privacy and security of your personal information.

1.2 This notice applies to all applicants who have applied to be engaged (whether temporarily or permanently) by, or to carry out work experience or a work placement with any entity in the Capital Generation Group which shall include Capital Generation Partners LLP, Capital Generation Holdings LLP, Capital Generation Investments LLP, Capital Generation Partners Services Limited and any of their respective subsidiaries, holding companies or subsidiaries of their holding companies. For the avoidance of doubt, the words “subsidiary” and “holding company” shall have the meanings attributed to them by the Companies Act 2006. It shall also include any director, officer, member, partner, employee, consultant or agent of any of the foregoing entities.

1.3 This privacy notice describes how we collect and use personal information about you during and after the application process, and during and after any work experience or work placement you undertake with us.

1.4 If your application to be engaged by Capital Generation Partners Services Limited (or any entity in the Capital Generation Group) is successful and you are engaged as an employee, worker or contractor of Capital Generation Partners Services Limited (or any entity in the Capital Generation Group), your personal information will be collected, used and retained in accordance with our Privacy Notice for Employees, Workers and Contractors and Employee Data Retention Policy, a copy of which is available upon request.

1.5 For more information about our approach to data protection, please see our Employee Data Protection Policy which is available on request.

1.6 The contents of this Privacy Notice for Applicants and our Employee Data Protection Policy are overseen by Sharon Chambers, Director, Finance & Office Management, whose contact details are below:

Email: sharon.chambers@capgenpartners.com

Telephone: (0)20 7543 1500

1.7 This is a policy document only and does not have contractual effect. This privacy notice may change from time to time and, if it does, the up to date version will always be available on request. We will also tell you about any important changes to our privacy notice.

2 HOW WILL WE USE YOUR PERSONAL DATA?

2.1 We will collect, store, use and share information about you in order to process your application, to assess your suitability for the position or placement you have applied for, to carry out our activities as a business, and to carry out our obligations as a prospective employer or a prospective work experience/work placement provider. If your application for work experience or a work placement is successful, we may also collect, store, use and share information about you in order to carry out our activities and obligations as a work experience or work placement provider.

2.2 We will normally only do this where:

(a) it is necessary in order to comply with legal obligations which apply to us;

(b) it is necessary for the performance of your employment contract (including for the provision of any employee benefits that you elect or are awarded as part of your employment with us);

(c) it is necessary in order to fulfil our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or

(d) the law otherwise permits or requires it.

2.3 We may also use your personal information in the following situations, which are likely to be rare:

(a) where we need to protect your interests (or someone else’s interests).

(b) where it is needed in the public interest.

2.4 In addition to the information that you provide to us, we may also collect, store and use information using the following means:

(a) when you apply for employment or a work placement, through undertaking our pre-employment checks including through the use of an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies, the police and our regulators.

(b) CCTV, which we may use for the purposes of ensuring safety and for the prevention and detection of crime. Where we collect information through our use of CCTV we will only do so in compliance with our legal obligations. Individuals will be notified by appropriate signage when CCTV is in operation. Access to data recorded by our CCTV system is restricted to those who require it for the purposes for which it is obtained. CCTV recordings are stored securely, in a way that maintains integrity and are retained for no longer than is necessary.

(c) monitoring of your use of our IT systems, which includes our telephone systems. We will only ever monitor your use of our IT in compliance with our IT Policy.

(d) During any work experience or work placement you undertake with us, we may also collect personal information about you in the course of work-related activities throughout the period of your work experience or work placement with us.

2.5 The tables at Schedule 1 and Schedule 2 set out the type of information we may collect and what it may be used for, but some of the grounds for processing referred to in that table will overlap and there may be several grounds which justify our use of your personal information.

2.6 If you fail to provide certain information when requested, this may prevent us from being able to process your application and/or to enter into a contract with you and/or to perform any contract we have entered into with you, or we may be prevented from complying with our legal obligations.

2.7 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

2.8 Data protection legislation identifies certain “special categories” of data, including information about race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, medical conditions, genetics, biometrics and criminal convictions. We may use such information in the following ways:

we will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to provide appropriate adjustments to the workplace or during the recruitment process.

2.9 We do not need your consent if we use special categories of your personal information to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with details of the information that we would like and the reason(s) we need it, so that you can consider whether you wish to consent.

2.10 We will usually only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally permitted to do so. Where appropriate, we may collect information about criminal convictions as part of the recruitment process.

2.11 We do not envisage that any decisions will be taken about you using automated means. We will notify you in writing if this position changes.

3 WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

3.1 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

3.2 “Third parties” includes third-party service providers (including contractors and designated agents), legal or regulatory bodies, and other entities within our group.

3.3 The following activities are carried out by third-party service providers: pensions administration, payroll administration and criminal records and other verification checks.

3.4 We will share your personal information with other entities in our group and associated entities, for example as part of our regular reporting activities on company performance and business planning, for system maintenance support and for hosting of data.

3.5 We may also share your personal information with other third parties, for example if a business transfer or change of business ownership takes place or is envisaged.

3.6 In addition, to comply with our legal, statutory and regulatory obligations we may need to share your personal information with a regulator (including the Financial Conduct Authority), HMRC, the Disclosure and Barring Service and other legal or regulatory bodies.

3.7 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 data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

4 HOW WE PROTECT YOUR DATA

4.1 We have put in place appropriate physical, technical and organisational security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

4.2 We aim to limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. This will include our HR team, your supervisor during any work placement and other employees who need the information to perform their management or administrative functions

5 HOW LONG DO WE KEEP YOUR PERSONAL DATA?

5.1 We will only retain your personal information for as long as we consider it necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Employee Data Retention Policy, which is available on request.

5.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, the applicable legal requirements and other factors that we consider relevant.

5.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

5.4 If your application is unsuccessful, we will retain your personal information for 6 months after we have communicated to you our decision concerning your application. We retain your personal information for that period so that we can demonstrate that the recruitment exercise has been carried out in a fair and non-discriminatory way.

5.5 After that period, we will securely destroy your personal information in accordance with policy and applicable laws and regulations.

5.6 Unsuccessful applicants may request that we retain their personal information on file for a longer period of time so that they may be considered for future vacancies. We may also wish to retain your personal information on file so that you can be considered for future vacancies. If we wish to do this, we will write to you to seek your consent.

5.7 If your application for work experience or a work placement is successful, we will retain your personal information for 6 months after your work experience or work placement ends, after which we will securely destroy your personal information in accordance with our Employee Data Retention Policy.

5.8 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

5.9 As noted above, if your application to be engaged by us (or any of our subsidiaries or associated entities) is successful and you are engaged as an employee, worker or contractor, your personal information will be collected, used and retained in accordance with our Privacy Notice for Employees, Workers and Contractors and Employee Data Retention Policy, a copy of which is available upon request.

6 TELLING US ABOUT CHANGES

6.1 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the application process and during any work experience or work placement you carry out with us.

7 WHAT ARE YOUR RIGHTS?

7.1 Under certain circumstances and subject to certain conditions, 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.
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. This 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 a 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. 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.

7.2 You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive (for example if you make multiple similar requests). Alternatively we may refuse to comply with your request in such circumstances.

7.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

7.4 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing. To withdraw your consent, please contact Sharon Chambers, our Head of Finance & Office Administration. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

8 HOW CAN YOU ASK FOR MORE INFORMATION?

8.1 If you have any questions or concerns about how we handle your personal information, please contact the HR team.

8.2 If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to make a complaint to the Information Commissioner’s Office (ICO). The ICO is the authority in the UK which is tasked with the protection of personal data and privacy.

Schedule 1

Applicants

TYPE OF PERSONAL DATA	LEGAL BASIS FOR PROCESSING	WHAT IT MAY BE USED FOR
Personal contact details such as name, title, address, telephone numbers and personal email address	Performance of your employment contract. Fulfil our legitimate interests (or those of a third party). Compliance with our legal obligations.	To contact you and to verify your identity
Date of birth	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	For equal opportunity monitoring and reporting, to ensure compliance with our legal obligations, and for business management and planning.
Gender	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	For equal opportunity monitoring and reporting, and to ensure compliance with our legal obligations
Emergency contact information	Fulfil our legitimate interests (or those of a third party). Protection of your interests.	To contact your next of kin in the event of an emergency
Government identification numbers (e.g. national insurance, driving licence, passport)	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To verify your identity, to administer payroll and benefits accurately, and to comply with our legal obligations
Bank account details	Compliance with our legal obligations.	To pay your expenses
Employment records (including job titles and work history)	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To ensure and evidence suitability for the role and for business management and planning
Education and training records	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To ensure you have the correct qualifications and skills to perform the role
Professional membership records	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To ensure you have the relevant memberships required or desirable in order to perform the role for which you are applying and for business management and planning
References, CVs, cover letters and work history	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To ensure and evidence your suitability for your role. To comply with regulatory obligations.
Proof of work eligibility	Compliance with our legal obligations. Fulfil our legitimate interests (or those of a third party).	To ensure you have the right to work in the UK
Location data (through building entry/exit records)	Fulfil our legitimate interests (or those of a third party). Protection of your interests.	To ensure building security, for use in emergency evacuation scenarios and for business management and planning
Health records	Necessary for the purposes of performing or exercising obligations or rights which are imposed on the employer or employee in connection with employment. Necessary for the establishment, exercise or defence of legal claims. Necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee.	To ensure safety in the workplace, to provide appropriate workplace adjustments to the recruitment process and to ensure compliance with our legal obligations
CCTV footage	Fulfil our legitimate interests (or those of a third party).	To ensure building security
Criminal records checks	Necessary for the purposes of performing or exercising obligations or rights which are imposed on the employer or employee in connection with employment.	To ensure and evidence your suitability for your role and to comply with our legal and regulatory obligations

Please note that, in the event of a dispute between us and you, any of the information set out above may be used to establish and defend a legal claim.

Schedule 2

Work experience/work placement

TYPE OF PERSONAL DATA	LEGAL BASIS FOR PROCESSING	WHAT IT MAY BE USED FOR
Emergency contact information	Performance of your employment contract. Fulfil our legitimate interests (or those of a third party). Protection of your interests.	To contact your next of kin in the event of an emergency
Government identification numbers (e.g. national insurance, driving licence, passport)	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To verify your identity, to administer payroll and benefits accurately, and to comply with our legal obligations
Bank account details, payroll information and tax status information	Compliance with our legal obligations. Performance of your employment contract.	To pay you and administer benefits, and to ensure compliance with legal obligations
Performance and conduct information	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To monitor, assess and improve workplace performance and conduct and for business management and planning. To comply with regulatory obligations.
Start date	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To ensure your employment rights are respected, to ensure you receive the correct benefits and to monitor your length of service in order to comply with our legal obligations
Professional membership records	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To ensure you have the relevant memberships required or desirable in order to perform your role and for business management and planning
Photograph	Fulfil our legitimate interests (or those of a third party).	To verify your identity and for communications purposes
Location data (through building entry/exit records)	Fulfil our legitimate interests (or those of a third party). Protection of your interests.	To ensure building security, for use in emergency evacuation scenarios and for business management and planning
IT records (including information about your use of our information and communication systems)	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To ensure network and information security and, if necessary, to detect and prevent inappropriate usage
Telephone records	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To ensure network and information security and, if necessary, to detect and prevent inappropriate usage
Health records	Necessary for the purposes of performing or exercising obligations or rights which are imposed on the employer or employee in connection with employment. Necessary for the establishment, exercise or defence of legal claims. Necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee.	To ensure employee safety in the workplace, to provide appropriate workplace adjustments and to ensure compliance with our legal obligations
Attendance records	Compliance with our legal obligations. Performance of your employment contract. Fulfil our legitimate interests (or those of a third party).	To monitor attendance levels, to ensure employee safety in the workplace and to provide appropriate workplace adjustments
CCTV footage	Fulfil our legitimate interests (or those of a third party).	To ensure building security

Please note that, in the event of a dispute between us and you, any of the information set out above may be used to establish and defend a legal claim.

Privacy Notice for Applicants (including work experience and work placement students)

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