Candidate Privacy Notice

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What is the purpose of this document?

Spire Management Limited and Spire Partners LLP (“Spire”) are “data controllers”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

 

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 for as long as is 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 in your curriculum vitae and covering letter to include work history and data, qualifications/certifications.
• Any information you provide to us during an interview and any test results.

We may also collect, store and use the following types of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your compensation: for example, your basic salary, benefits, bonuses.
• Evidence of your right to work, nationality e.g. passport, driving licence and National Insurance number).
• Information about your health, including any medical condition, health and sickness records.
• Results from pre-employment screening checks (e.g. credit history, criminal records checks where permitted under local law).

How is your personal information collected?
We collect personal information about candidates from the following sources:

• You, the candidate.
• Our partner recruitment agency(s).
• Your named referees.

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

It is in our legitimate interests to decide whether to appoint you to work since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract with you.

Failing 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
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, for example whether adjustments need to be made during a test or interview.
• We will use information about your 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.

Information about criminal convictions
We do not envisage that we will process information about criminal convictions however, given the nature of the business we have a legal and regulatory duty to make sure people we employ can be relied upon to handle client money and information responsibly.

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: right to work agencies who will carry out background checks about you, with your consent. 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 data for their own purposes. We only permit them to process your personal data 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?
In addition to using your personal information for the position for which you have applied, we may retain and use your personal information to consider you for other positions. If you do not want to be considered for other positions or would like to have your personal data removed, you may contact us by emailing contact@spirellp.com. Once we have communicated to you our decision about whether to appoint you to work we will retain your personal information 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. Should you wish us to remove your data, we will securely destroy your personal information in accordance with applicable laws and regulations.

 

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. 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.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.

Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please email contact@spirellp.com
Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

 

I,___________________________ (candidate name), acknowledge that on _________________________ (date), I received a copy of Spire’s Candidate Privacy Notice and that I have read and understood it.

Signature ………………………………………………

Name

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