Privacy Notice – Recruitment

Privacy Notice - Recruitment

A. Data Protection Privacy Notice (Recruitment)

1. This Privacy Notice (Recruitment) explains what personal data we will hold about you, how we collect it, and how we will use and may share personal data we hold about you during the application process. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice and any other information we may provide to you from time to time when we collect or process personal information about you.

B. Who collects the information

Patron Capital Advisers LLP is a ‘controller’ in relation to the personal data that we collect about you. This means that we are responsible for deciding how we hold and use personal data. Personal data that we collect and hold on your behalf may also be used by our affiliated entities and group companies as part of your application process, namely Patron Capital Europe S.à.r.l., Patron Investments II S.à.r.l, Patron Investments III S.à.r.l, Patron Capital Investments S.à.r.l, Patron Capital, L.P. II, Patron Capital, L.P. III, Patron Capital L.P. IV, Patron Capital, V L.P., Patron Capital, VI L.P., Patron Capital, VII L.P. and any future Patron Capital Funds (our ‘group companies’) and so, in this notice, references to ‘we’ or ‘us’ mean Patron Capital Advisers LLP and our group companies.

C. Data protection principles

We will comply with the following data protection principles when gathering and using personal data:
- we will process personal data lawfully, fairly and in a transparent way;
- we will collect personal data for specified, explicit and legitimate purposes only, and will not process it in a way that is not compatible with those legitimate purposes;
- we will only process the personal data that is adequate, relevant and necessary for the relevant purposes;
- we will keep accurate and up to date personal data, and take reasonable steps to make sure that inaccurate personal information is deleted or corrected without delay;
- we will keep personal data for no longer than is necessary for the purposes for which the personal data is processed; and
- we will take appropriate technical and organisational measures to make sure that personal data is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

D. What information

We may collect the following categories of personal data from you in connection with your application, up to and including the shortlisting stage of the recruitment process:
- Your name and contact details (i.e. address, home and mobile phone numbers, email address);
- Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
- Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- Information regarding your criminal record;
- Details of your referees; and/or
- Any additional information you provide to use during the interview process.
We may collect the following information after the shortlisting stage, and before making a final decision to recruit:
- Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
- Information regarding your academic and professional qualifications;
- Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs);
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information; and/or
- A copy of your driving licence,
You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked above to us to enable us to verify your right to work and suitability for the position.

E. How we collect the information

We will collect this information from:
- you directly;
- your referees (details of whom you will have provided);
- your education provider;
- the relevant professional body;
- your recruitment agency;
- the Disclosure and Barring Service (DBS); and
- the Home Office.

F. Why we collect the information and how we use it

We will typically collect and use this information for the following purposes:
- to make an informed recruitment decision;
- to carry out a fair recruitment process;
- to maintain employment records;
- to assess your skills, qualifications, and suitability for the role;
- to carry out background and reference checks, where applicable;
- to progress your application and communicate with you about the recruitment process, for example, to contact you to arrange interviews and inform you of the outcome;
- to inform the relevant manager or department of your application;
- to keep records related to our hiring processes;
- to carry out statutory checks;
- to comply with legal or regulatory requirements (e.g. our obligation to check that you are eligible to work in the United Kingdom);
- to verify the qualifications information provided by you;
- to comply with our equal opportunities monitoring obligations and to follow our equality and other policies; and
- to ensure you have a clean driving licence.
We may rely on any of the following lawful basis (or bases) to process the information:
- for the purposes of entering into a contract of employment with you;
- for compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom);
- for the performance of a task carried out in the public interest; and
- for the purposes of our legitimate interests, on the basis that our decision to appoint you to the relevant role is beneficial to the conduct of our business, however we will only rely on this basis provided our interests are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

G. Failure to provide information

If you fail to provide information when requested, and 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.

H. How we use sensitive personal data

Where appropriate we will use your sensitive personal information in the following ways:
- We use information about racial or ethnic origin, religious or philosophical beliefs, disability or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.
- We use information about disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.

I. How we may share the information

We may also need to share some of the above categories of personal data with other parties, such as HR consultants and professional advisers for the purposes of processing your application. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

J. International transfers

For the purposes of processing your application, we may transfer personal data to third party services providers outside of the European Economic Area (EEA) (which comprises the countries in the European Union and Iceland, Liechtenstein and Norway). In these circumstances, we will ensure that appropriate safeguards are in place, including:
- We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data
- We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK

K. Sensitive personal information and criminal records information

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Data Protection Policy, Data Protection Privacy Notice and Criminal Records Information Policy. All policy documents are contained in our staff handbook, which is available from the Chief Operating Officer or General Counsel.

L. Where information may be held

Information may be held at our offices and those of our group companies and third party agencies, service providers, representatives and agents as described above.

M. How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept. For further information, see our Retention Policy which is available from the Chief Operating Officer or General Counsel.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see our Data Protection Privacy Notice which is available from the Chief Operating Officer or General Counsel.

N. Your rights to correct and access your information and to ask for it to be erased

Under the UK GDPR, you have a number of rights in relation to your personal data. You have the right to:
- Request access to your personal data;
- Request correction of the personal data that we hold about you that inaccurate or incomplete;
- Request erasure of your personal data. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to processing of your personal data where we are relying on legitimate interest as the legal basis for the use of your data;
- Object to the processing of your personal data for direct marketing purposes;
- Request restriction of how we process your personal data; and/or
- Request the transfer of your personal data to you or a third party.
If you wish to exercise any of the rights set out above, please contact the Chief Operating Officer or General Counsel, who can be contacted on 0207 629 9417

O. Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it.

P. How to complain

We hope that the Chief Operating Officer or General Counsel can resolve any query or concern you raise about our use of your personal data or any questions you may have in relation to this privacy notice. You can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.