Interactive Investor Services Limited
Candidate privacy notice
What is the purpose of this document?
Interactive Investor Services Limited (“ii”) is a "data controller". This means that ii are responsible for deciding how ii hold and use personal information about you. You are being sent a copy of this privacy notice 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
- ii 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 ii have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes ii 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 ii have told you about.
- Kept securely.
The kind of information ii hold about you
In connection with your application for work with us, ii will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided as part of your application, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
- Any information you provide to us during an interview.
ii may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your race or ethnicity.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
ii collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies, from which ii collect the following categories of data, name, previous career experience, qualifications, proof of right to work, any other information as detailed on your CV.
- Background check providers, from which ii collect the following categories of data, Experian for fraud checks (first name, surname, birth date, NI number, telephone number and work telephone number, email address, address history, )and Experian for sanctions, PEP and media (first name, surname and date of birth.
- Experian the credit reference agency, from which ii collect the following categories of data: Title, first name, middle name, surname, date of birth, current address, previous address history and previous names.
- Experian for Disclosure and Barring Service in respect of criminal convictions. If this is for a regulated SMCR role, there will be a Standard Criminal Check via Experian together with a regulated reference via Experian.
- Your named referees, from whom ii collect the following categories of data: employment dates, last position held and reason for leaving and other additional information provided such as performance.
- Please note that screening is not undertaken until an offer is accepted and permission is received from the person/candidate in question.
How ii will use information about you
ii will use the personal information ii 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 hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role.
ii 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 and the results from any test which you took as part of the recruitment process, ii will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, ii will decide whether your application is strong enough to invite you for an interview. If ii decide to call you for an interview, ii will use the information you provide to us at the interview to decide whether to offer you the role. If ii decide to offer you the role, ii will then take up references and carry out a criminal record check, fraud check, credit check, sanctions, PEP and media check, right to work check and reference check before confirming your appointment.
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), ii will not be able to process your application successfully. For example, if ii require a credit check or references for this role and you fail to provide us with relevant details, ii will not be able to take your application further.
How ii use particularly sensitive personal information
ii will use your particularly sensitive personal information in the following ways:
- ii will use information about your disability status to consider whether ii need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview .
- ii will use information about your race or national or ethnic origin, age, gender and disability status to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
ii envisage that ii will process information about criminal convictions.
ii will collect information about your criminal convictions history if ii would like to offer you the role conditional on checks and any other conditions, such as references, being satisfactory. ii are required 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:
- The role requires a high degree of trust and integrity working in Financial Services and so we would like to ask you to seek a basic disclosure of your criminal records history.
ii have in place an appropriate policy document and safeguards which ii are required by law to maintain when processing such data.
Why might you share my personal information with third parties?
ii will only share your personal information with third parties to the extent necessary for the purposes of processing your application, such as recruitment agencies and recruitment platforms used to process applications and also screening/security checking services. 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. ii do not allow our third-party service providers to use your personal data for their own purposes. ii only permit them to process your personal data for specified purposes and in accordance with our instructions.
ii 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, ii limit access to your personal information to those employees, agents, contractors and other 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. Details of these measures may be obtained from the Data Protection Officer (DPO).
ii 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 ii are legally required to do so.
How long will you use my information for?
ii will retain your personal information for a period of 6 months after ii have communicated to you our decision about whether to appoint you to the role. ii retain your personal information for that period so that ii can show, in the event of a legal claim, that ii have not discriminated against candidates on prohibited grounds and that ii have conducted the recruitment exercise in a fair and transparent way. After this period, ii will securely destroy your personal information in accordance with our data retention policy.
If ii wish to retain your personal information on file, on the basis that a further opportunity may arise in future and ii may wish to consider you for that, ii 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 ii hold about you and to check that ii are lawfully processing it.
- Request correction of the personal information that ii hold about you. This enables you to have any incomplete or inaccurate information ii 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 ii 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 ii transfer a copy of your personal information to another party, please contact Human Resources in writing.
Right to withdraw consent
When you applied for this role, you provided consented to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Recruitment Manager. Once ii have received notification that you have withdrawn your consent, ii will no longer process your application and, subject to our retention policy, ii will dispose of your personal data securely.
Data protection officer
ii have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how ii handle your personal information, please contact the DPO. 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.