Privacy notice - recruitment

A. Data Protection Privacy Notice (Recruitment)

  1. This Privacy Notice (Recruitment) explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information 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 similar notice 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 'data controller' and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, 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. (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

  1. We will comply with the following data protection principles when gathering and using personal information:
    • we will process personal information lawfully, fairly and in a transparent way;
    • we will collect personal information 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 information that is adequate, relevant and necessary for the relevant purposes;
    • we will keep accurate and up to date personal information, and take reasonable steps to make sure that inaccurate personal information is deleted or corrected without delay;
    • we will keep personal information for no longer than is necessary for the purposes for which the information is processed; and
    • we will take appropriate technical and organisational measures to make sure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

D. What information

  1. We may collect the following information 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.
  2. 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 ◻;
    • A copy of your driving licence ◻.
  3. 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

  1. We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service (DBS) and the Home Office.

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

  1. 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.
  2. We may rely on any of the following lawful basis (or bases) to process the information:
    • to take steps to enter into a contract;
    • for compliance with a legal obligation (eg 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, but only if these are not overridden by your interests, rights or freedoms.
  3. 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. How we may share the information

  1. We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.

H. International transfers

  1. We may transfer personal information outside the European Economic Area (EEA) (which comprises the countries in the European Union and Iceland, Liechtenstein and Norway) to other countries on the basis that the organisation receiving the information has provided adequate safeguards to us.

I. Sensitive personal information and criminal records information

  1. 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, available from Shane Law or Kendall Langford.

J. Where information may be held

  1. 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.

K. How long we keep your information

  1. 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.
  2. 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 Shane Law or Kendall Langford.
  3. 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 Shane Law or Kendall Langford.

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

  1. Please contact Shane Law or Kendall Langford, who can be contacted on 0207 629 9417 / shane@patroncapital.com or (020) 7629 9417 / kendall@patroncapital.com if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask Shane Law or Kendall Langford for some but not all of the information we hold and process to be erased (the 'right to be forgotten') in certain circumstances. Shane Law or Kendall Langford will provide you with further information about the right to be forgotten, if you ask for it.

M. Keeping your personal information secure

  1. 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.

    Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

  2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

N. How to complain

  1. We hope that Shane Law or Kendall Langford can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.