Recruitment Privacy Notice
Data controllers: Liontrust Asset Management Plc, Liontrust Investment Partners LLP and Liontrust Fund Partners LLP of 2 Savoy Court, London, United Kingdom, WC2R 0EZ.
When we use the term “Liontrust” in this recruitment privacy notice (or “we”, “us” or “our”), we mean any of Liontrust Asset Management Plc, Liontrust Investment Partners LLP and Liontrust Fund Partners LLP which each acts as a controller of personal data (as detailed above) and is legally responsible for deciding how and for what purpose your personal data is used.
Who does this staff privacy notice cover?
This staff privacy notice covers all individuals who are applying to working for Liontrust in any capacity including workers, employees, members, consultants and as agency workers. We will use the term “candidates” in this staff privacy notice (or “you” or “your”).
We collect and process personal data relating to candidates to manage their recruitment process with Liontrust. Liontrust is committed to being transparent about how it collects and uses that data and to meeting our data protection obligations.
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 your recruitment process with us.
We reserve the right, at our discretion, to change, modify, add to, or remove portions from, this privacy notice. We will of course notify you of any changes where we are required to do so.
What information do we collect?
Liontrust collects and processes a range of personal data about you, including some special categories of personal data.
We collect personal information about candidates from the following sources (if applicable):
- you, the candidate;
- the recruitment agency;
- the background check provider;
- credit reference agency;
- Disclosure and Barring Services in respect of criminal convictions;
- your named referees; and
- the following data from third parties is from a publicly accessible source.
This includes the following types of data:
- the information you have provided in your CV and covering letter;
- the information you have provided in any application form, including your name, title, address, telephone number, gender, date of birth, personal email address, education history, qualifications, skills; professional memberships; experience and employment history, employment references including start and end dates, with previous employers;
- the information contained in your ID documents including your passport or driving licence;
- information about your nationality, citizenship and entitlement to work in the jurisdiction in which you are applying to work in;
- any information you provided to us during as part of the interview process (including during your interview);
- information about you which has been provided to us by the third parties set out above (including the relevant recruitment agency and background check provider);
- information about your race or ethnicity; religious or philosophical beliefs, trade union membership, sexual orientation and political opinions;
- information about your health, including any medical condition, health and sickness records;
- information about your criminal record and copies of credit history or bankruptcy checks as required for regulatory purposes;
- equal opportunities monitoring information, including information about your nationality and ethnic origin;
- CCTV footage and other information obtained through electronic means;
- records of all communications including recordings of phone calls and electronic communications which we record.
Liontrust seeks information relating to your engagement from third parties with your consent only.
Data is stored in a range of different places, including in your paper and electronic files, in Liontrust’s HR systems, IT systems (including the Liontrust's email system) and other Liontrust work-related systems.
Why do we process personal data?
Liontrust needs to process your data to conduct its recruitment process with you. We need to process your data to (where applicable):
- assess your skills, qualifications, and suitability for the work;
- carry out background and reference checks;
- communicate with you about the recruitment process;
- keep records relating to our hiring processes;
- consider whether we need to provide appropriate adjustments during the recruitment process; and
- ensure meaningful equal opportunities monitoring and reporting.
In some cases, Liontrust needs to process data to ensure that we are complying with our legal obligations. For example, we are required to check your entitlement to work in a specific location. It is necessary to carry out criminal record checks for regulatory purposes to ensure that individuals are permitted to undertake the role in question.
Liontrust has a legitimate interest in processing personal data about you to decide whether to appoint you to the role you are applying for since it would beneficial to our business to appoint someone into that role.
We also need to process your personal information to decide whether to enter into a contract with you.
You will not be subject to decision that will have a significant impact on you based solely on automatic decision-making (including profiling).
Who has access to data?
Your information may be shared with Liontrust group companies, other departments internally, including with members of the HR team, the line manager for the role we are recruiting for and anyone within that line of reporting in the area in which you would work if successful in being appointed to the role.
We may also share your data with third parties that process data on Liontrust’s behalf in connection with your recruitment process with us, including for example to obtain references from other companies, obtain background checks from third-party providers and obtain necessary criminal records checks.
Where those entities are data processors, they are required to take appropriate security measures to protect your personal information in line with the Liontrust’s policies and procedures relating to data protection and they are only allowed to process your personal data for specified purposes and in accordance with our instructions. Some third parties may be data controllers, in which case they will follow their own procedures in relation to your data.
In some cases, Liontrust may also be required to share your data with governmental authorities:
- Liontrust may disclose to law enforcement agencies and regulators, government departments or competent authorities of the UK or of other countries, any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) where Liontrust is under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our customers or others. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.
- Liontrust may disclose your information if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC) or other tax authorities, who may transfer it to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.
Liontrust will not normally transfer your data to countries outside of the UK or the European Economic Area. There could be rare occasions when we need to engage with third parties who, from time to time, manage data in a country outside of the UK or EEA. For example, this may be when we need to perform pre-employment checks if you have lived and worked overseas.
How does Liontrust protect data?
Liontrust takes the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our staff members in the performance of their duties.
Where Liontrust engages third parties to process personal data on our behalf, we do so on the basis of written instructions, are under a duty of confidentiality and we are obliged to implement appropriate technical measures to ensure the security of data.
For how long do we keep data?
Liontrust will hold your personal data for the duration of your recruitment process with us. When your recruitment process with us ends and you are unsuccessful in securing a role with Liontrust, we will review all the records we hold and ensure that any data we consider to be unnecessary for the purposes noted above are deleted.
If you are successful in securing a role with Liontrust, your data will be kept in accordance with our Staff Privacy Notice which will be provided to you when you start working for us.
Where possible, any records we retain will be anonymised or pseudonymised.
Your rights
As a data subject, you have several rights. You can:
- access and obtain a copy of your data on request;
- request that we change incorrect or incomplete data;
- request (in certain circumstances) that we delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- withdraw consent to the processing of your data where Liontrust is relying on consent as the legal ground for processing;
- in certain circumstances, receive from us any personal data concerning you in a structured, commonly used and machine-readable format, and request that we transmit it directly to another data controller, where technically feasible; and
- ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Liontrust's legitimate grounds for processing data.
Responses to requests to access and obtain a copy of your data under UK GDPR are free. However, please be aware that if a request is considered manifestly unfounded, excessive or repetitive, we reserve the right to charge a reasonable fee for access. We will respond to your request within one month of receipt of your request. In certain cases, this may not be possible (for example, if the request covers a wide range of information and sources or systems) in which case we will inform you of this and the timeframe within which we will be able to respond.
Should you have any concerns about how we process your personal data you should contact us. You also have the right to lodge a complaint with the Information Commissioner’s Office, details below.
What if you do not provide personal data?
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 the role and you fail to provide us with relevant details, we will not be able to take your application further.
Questions and Concerns
If you have any questions or concerns about Liontrust's handling of your personal data, or about this privacy notice, please email us at dataprotection@liontrust.com.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you have the right to complain to the local data protection commission who has enforcement powers and can investigate compliance with data protection law.
For the UK : Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
