Job Applicant Privacy Notice
As part of any recruitment process, Tower Research Capital Europe (“TRCE”) collects and processes personal data relating to job applicants. The company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the company collect?
TRCE collects a range of information about you. This includes:
your name, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history;
information about your current level of remuneration, including benefit entitlements;
whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process;
information about your entitlement to work in the UK; and
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or beliefs.
TRCE collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The company will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the TRCE process personal data?
TRCE needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
TRCE has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the company to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. TRCE may also need to process data from job applicants to respond to and defend against legal claims.
The company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the company processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.
For some roles, TRCE is obliged to seek information about criminal convictions and offences. Where the company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, TRCE will keep your personal data on file for a period of time, in case there are future employment opportunities for which you may be suited.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
TRCE will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.
Transfers of personal data outside the EEA?
In connection with our business and for employment, administrative, management and legal purposes, we will where necessary and as set out in this privacy notice transfer your personal data outside the EEA to members of our group and data processors in other jurisdictions in which we are established. We will ensure that any transfer is lawful and that there are appropriate security arrangements.
In relation to intra-group transfers, the members of the Tower Group of companies have entered into agreements ensuring appropriate and suitable safeguards with Tower Group’s controllers/processors outside the EEA. These are in standard terms approved by the European Commission. If you wish to see details of these safeguards, please ask of Head of Compliance, Alistair McGrath (firstname.lastname@example.org).
How does TRCE protect data?
TRCE takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does TRCE keep data?
We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes.
As a data subject, you have a number of rights. You can:
access and obtain a copy of your data on request;
require TRCE to change incorrect or incomplete data;
require TRCE to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where TRCE is relying on its legitimate interests as the legal ground for processing; and
ask TRCE to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact our Head of Compliance, Alistair McGrath (email@example.com). You can make a subject access request by completing the organisation's form for making a subject access request.
If you believe that TRCE has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to TRCE during the recruitment process. However, if you do not provide the information, the company may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
Recruitment processes are not based solely on automated decision-making.