Welcome to Jarvis's Candidate privacy notice

Jarvis respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. If you have any queries about the process or how we handle your information, please contact us at: HRdataprivacy@jarvisim.co.uk

What is the purpose of this document?

Jarvis Investment Management Ltd (Jarvis) is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are either being sent a copy of this privacy notice or have been directed to our website 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 as long as necessary for the purposes we have told you about.
• Kept securely.

The kind of information we hold about you

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

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 provided to us in your curriculum vitae and covering letter.
• Any information you provide to us during an interview.

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

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates from the following sources:

• You, the candidate.
• Recruitment agencies.
• Disclosure and Barring Service in respect of criminal convictions, if applicable for the role you are applying for.
• Your named referees, from whom we collect the following categories of data: confirmation of previous employment dates, job title, attendance record, performance and reason for leaving role

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

We also need to process your personal information to decide whether to enter into a contract of employment with you.

Having received your CV and covering letter, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and/or carry out preemployment checks as required for the role. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

We will not use the personal information we collect about you for any direct marketing purposes.

If you fail 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 criminal records 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 an interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

We will process information about criminal convictions if applicable for the role.

We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

• We are legally required by the Financial Conduct Authority (FCA) to carry out criminal record checks for certain functions. Certain roles may require a high degree of trust and integrity so we may ask you to seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

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?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

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.

Where any of our external third parties are based outside the European Economic Area (EEA), who provide IT and system administration services for our company, their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please e-mail: HRdataprivacy@jarvisim.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 and specific 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?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment, plus 6 years following the end of your employment.

If you are unsuccessful at any stage of the process, we will retain your personal information for a period of 6 months after we have communicated our decision to you. We retain your personal information for that period 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. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

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.
• 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 HRdataprivacy@jarvisim.co.uk in writing.

Right to withdraw consent

You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please e-mail: HRdataprivacy@jarvisim.co.uk. 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.

If you have any questions about this privacy notice or how we handle your personal information, please e-mail: HRdataprivacy@jarvisim.co.uk. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.