Applicant Privacy Notice
1. About this notice
1.1 Benchmark Capital Limited and / or the relevant Benchmark Group company recruiting for the role (“Benchmark”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal data.
This Applicant Privacy Notice explains:
- What personal data we collect about job applicants;
- How we use that information;
- The legal basis we rely upon for processing;
- Who we share the information with;
- How long we retain it; and
- Your rights under UK data protection law.
We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable privacy legislation.
2. Data Controller details
2.1 Benchmark Capital Limited, or relevant Benchmark Group company recruiting for the role, is the Data Controller for the personal data processed in connection with your application.
3. Data protection principles
3.1 In relation to your personal data, we will;
- Process it lawfully, fairly and transparently;
- Collect it only for specified, explicit and legitimate purposes;
- Ensure it is adequate, relevant and limited to what is necessary;
- Keep it accurate and up to date;
- Retain it only for as long as necessary;
- Keep it secure using appropriate technical and organisational measures; and
- Ensure it is not lost, misused or accessed without appropriate authorisation.
4. Types of personal data we process
4.1 We may collect and process the following categories of personal data:
- name, address and contact details;
- date of birth;
- right-to-work and immigration information;
- employment history and career information;
- academic and professional qualifications;
- references and referee details;
- interview notes;
- assessment results;
- remuneration expectations;
- gender and diversity monitoring information;
- information relating to reasonable adjustments; and
- information required for regulatory or background screening purposes where appropriate.
5. How we collect your personal data
5.1 We collect personal from you through:
- Application forms;
- CVs and covering letters;
- Email correspondence;
- Interviews;
- Assessments; and
- Communications during the recruitment process.
5.2 We may also collection information from:
- recruitment agencies;
- former employers and referees;
- qualification verification providers;
- right-to-work verification providers;
- background screening providers;
- publicly available sources; and
- regulatory databases where relevant to the role.
5.3 Your personal data is stored within Benchmark’s recruitment, HR and IT systems.
6. Why we process your personal data
6.1 We process your personal data for the following purposes:
- assessing your suitability for employment;
- managing and administering recruitment activities;
- arranging interviews and assessments;
- communicating with you regarding your application;
- verifying qualifications, employment history and references;
- conducting background and regulatory checks where required;
- complying with legal and regulatory obligations;
- making reasonable adjustments where required; and
- establishing, exercising or defending legal claims.
6.2 The legal bases we rely upon include:
- taking steps at your request prior to entering into an employment contract;
- compliance with legal obligations;
- Benchmark's legitimate interests in operating an effective recruitment process; and
- protection of vital interests where applicable.
6.3 Where we wish to retain your information to inform you of future opportunities, we will do so in accordance with applicable data protection requirements and provide an opportunity for you to opt out.
6.4 We process personal data where it is necessary for the legitimate interests of Benchmark, provided those interests are not overridden by your rights and freedoms. These legitimate interests include:
- assessing applications and determining candidate suitability;
- making recruitment and employment decisions;
- determining appropriate remuneration and benefits;
- planning training and development requirements;
- protecting Benchmark's legal rights and interests;
- investigating and responding to complaints or claims; and
- meeting regulatory and governance requirements, including FCA obligations.
6.5 If your application is unsuccessful, Benchmark may retain your personal data for the period set out in this notice in order to:
- provide feedback where appropriate;
- respond to queries or complaints relating to the recruitment process;
- protect and defend legal claims; and
- contact you regarding future employment opportunities where we believe the role may be suitable and were permitted by applicable law.
You may request at any time that we stop contacting you regarding future recruitment opportunities.
7. Special categories of personal data
7.1 During the recruitment process we may process special category personal data relating to:
- Health;
- Sex life;
- Sexual orientation;
- Race or Ethnic origins;
- Political opinions;
- Religious or philosophical beliefs;
- Trade union membership; and
- Genetic and biometric data.
7.2 We will only process special category personal data were permitted by law and where one or more of the following conditions applies:
- You have given explicit consent;
- Processing is necessary for carrying out our legal obligations and exercising specific rights in employment law;
- Processing is necessary for reasons of substantial public interest; or
- The information has manifestly been made public by you.
7.3 We may use special category personal data:
- For equal opportunities monitoring;
- To determine and facilitate reasonable adjustments throughout the recruitment process; and
- To comply with legal and regulatory obligations.
7.4 We do not require your consent where we process special category personal data to comply with our legal obligations or exercise specific rights under employment law.
7.5 Where consent is required, you will be informed of the purposes for which your information will be processed and may withdraw your consent at any time.
8. Criminal conviction data
8.1 We will only process criminal conviction data where appropriate for the role and were permitted by law. For example, criminal conviction information may be processed as part of Fit and Proper Declaration assessments, regulatory screening or background checks for Senior and/ or regulated roles in accordance with the FCA.
9. If you do not provide your data
9.1 You are not legally obliged to provide personal data during the recruitment process.
However, where information is necessary for us to assess your suitability for a role or comply with legal obligations, we may be unable to continue processing your application.
10. Sharing your data
10.1 Your information may be shared internally with individuals who have a legitimate business need to access it, including:
- Human Resources;
- hiring managers;
- interview panel members;
- Compliance;
- Legal; and
- IT personnel supporting recruitment systems.
10.2 Your personal data may also be shared with:
- recruitment agencies;
- reference providers;
- background screening providers;
- right-to-work verification providers;
- IT and recruitment system providers;
- professional advisers; and
- regulators, law enforcement agencies or courts where legally required.
10.3 All third parties are required to maintain appropriate security measures and process personal data only in accordance with applicable legal requirements. We do not share your data with bodies outside of the European Economic Area.
11. Protecting your personal data
11.1 Benchmark maintains appropriate technical and organisational measures to protect personal data against accidental loss, unauthorised disclosure, misuse, alteration or destruction.
11.2 Access to applicant information is restricted to authorised personnel with a legitimate business need to access the information.
12. How long we keep your data for
12.1 How long we retain your personal data will depend upon:
- the purpose for which it was collected;
- our legal and regulatory obligations; and
- our legitimate interests in establishing, exercising or defending legal rights.
12.2 In most cases, unsuccessful applicant information will be retained for six months following closure of the recruitment campaign. Where necessary, information may be retained for longer periods to comply with legal, regulatory or claims management requirements.
13. Automated decision making
13.1 Benchmark does not make decisions about applicants solely on the basis of automated decision making where those decisions produce legal or similarly significant effects
13.2 Where recruitment technologies are used to support screening or assessment activities, meaningful human review will take place before any recruitment decision is made.
14. Your rights
14.1 Under data protection law you have the right to:
- be informed about how your personal data is used;
- access your personal data;
- request correction of inaccurate or incomplete data;
- request erasure of personal data in certain circumstances;
- request restriction of processing;
- object to processing;
- request portability of certain personal data;
- withdraw consent where processing relies upon consent; and
- not be subject to unlawful automated decision making.
14.2 To exercise any of these rights, please contact:
Data Protection Officer
Email: dataprotection@benchmarkcapital.co.uk
15. How to contact us
15.1 If you have any questions about this Privacy Notice, how Benchmark uses your personal data, or if you wish to exercise any of your data protection rights, please contact us using the details below:
Data Protection Officer
Email: dataprotection@benchmarkcapital.co.uk
15.2 You may contact us to:
- request access to your personal data;
- request correction of inaccurate information;
- request deletion of your personal data where applicable;
- object to or restrict our processing of your personal data;
- withdraw consent where processing is based on consent; or
- ask any questions regarding the way your personal data is collected, used, shared or retained.
15.3 We are committed to resolving privacy concerns promptly and encourage you to contact us in the first instance so that we can investigate and address your concerns.
16. Making a complaint
16.1 If you are dissatisfied with our response or believe that we have not processed your personal data in accordance with applicable data protection legislation, you have the right to lodge a complaint with the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection matters.
16.2 You can contact and make a complaint with the ICO through their website: The Information Commissioner’s Office.
