JOB APPLICANT PRIVACY NOTICE

 

Data Controller:
Capital Select Limited
Capital House
Circular Road
Douglas
Isle of Man
IM1 1AG

Data Protection Officer
DPO@capital-iom.com
Capital Select Limited
Capital House
Circular Road
Douglas
Isle of Man
IM1 1AG

As part of any recruitment process, Capital Select Limited (“the Company”) collects and processes personal data relating to job applicants.

The Company is part of the Capital International Group Limited (the “Group”).  The “Group” refers to those entities within the Capital International Group Limited who are licensed by the Isle of Man Financial Services Authority and/or registered by the Isle of Man Information Commissioner.

What is the purpose of this document?

Capital Select Limited (the “Company”) is a “data controller”.  As defined by the Data Protection Act 2018, as amended from time to time, certain information must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

It is imperative that you read and retain this notice, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data Protection Principles

In accordance with the terms of the Data Protection Act 2018, as amended from time to time, the Company will comply with data protection law and principles (www.inforights.im).

The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the Company collect?

In connection with your application for work with us, the Company will collect, store, use and process a range of personal information about you, to include, but not limited to, the following items:

  • your name, address and contact details, including e-mail address and telephone number;
  • details of your qualifications, skills, experience and employment history with your previous employers (including start and end dates);
  • information about your current level of remuneration, including benefit entitlements such as pensions or insurance cover;
  • information about your entitlement to work in the Isle of Man or any other jurisdiction where the employment may be based;
  • the information you have provided to us in your curriculum vitae (CV) and covering letter;
  • information about your health, including any medical condition, health and sickness records;
  • information about criminal convictions and offences;
  • information you provide to us during the course of an interview; and
  • any other information provided to us about you (if applicable) by an employment agency and not otherwise listed above.

How is your personal information collected?

The Company collects this information in a variety of ways, for example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.  Data will be stored in specifically identified areas, for example, on your application records, on HR management systems and on other IT systems, including e-mail.

If your application is successful, the Company will also collect personal data about you from third parties, for example, references supplied by former employers, information from employment background check providers, as well as security and vetting checks.  The Company will seek information from third parties only once a job offer has been made to you and will inform you that it is doing so.

Why does the Company process personal data?

The Company processes personal data during the recruitment process and for keeping records of the process.  Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.  The Company may also need to process data from job applicants to respond to and defend against legal claims.

If your application is successful, the Company will need to process data to ensure that it is complying with its legal obligations, for example, it is required to check a successful applicant’s eligibility to work in the Isle of Man or any other jurisdiction where the employment may be based, prior to commencement of employment.

The Company will obtain and process personal data relating to health information if it needs to make reasonable adjustments to the recruitment process for candidates who may have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where relevant, the Company will seek information about possible criminal convictions and offences.  Where the Company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, the Company will retain your personal data on file for a period of six months in case there are future employment opportunities for which you may be suited.  The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise.  This includes, but is not limited to, members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff, if access to the data is necessary for the performance of their roles.

The Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.  The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and, where appropriate, the Disclosure and Barring Service, to obtain necessary criminal records checks.

If a situation arises whereby there is a requirement for your personal data to be transferred outside of the European Economic Area (EEA), it will be in compliance with the Group Data Sharing Agreement in place from time to time.

How will we use information about you?

We will use the personal information we collect about you to:

  • assess your skills, qualifications, and suitability for the work or 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.

Having received your CV and covering letter, we will then process that information only in relation to the requirements of the role.

Data Security

The Company takes the security of your data seriously.  Data breaches will be dealt with in accordance with the Group’s Data Security and Breach Policy and supporting procedures in place from time to time.

Further information is available from the Data Protection Officer who can be contacted via e-mail at DPO@capital-iom.com.

For how long does the Company keep data?

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained for the duration of your employment and in accordance with the Group Data Retention and Destruction Policy as amended from time to time.

If your application for employment is unsuccessful, the Company will retain your data on file for a period of six months after the end of the relevant recruitment process, in the event that any other employment opportunities arise for which you may be considered.

The Company will request your consent before it keeps your personal data for this purpose and you are free to withdraw your consent at any time.

At the end of that period, or once you withdraw your consent, if earlier, your personal data will be destroyed.

Your Rights

As a data subject, you have a number of rights.  You can:

  • access and obtain a copy of your data on request where there is a legitimate reason;
  • require the Company to change incorrect or incomplete data;
  • require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the Company is relying on its legitimate interests as the legal grounds for processing; and
  • ask the Company to stop processing data for a period, if data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data.

If you wish to exercise any of these rights or make a subject access request, please contact the Data Protection Officer via e-mail at DPO@capital-iom.com or address your correspondence to:

Data Protection Officer
Capital Select Limited
Capital House
Circular Road
Douglas
Isle of Man
IM1 1AG

If, following communication with the Company’s Data Protection Officer, you believe that the Company has not complied with your data protection rights, you can lodge a complaint with the Isle of Man Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Company during the recruitment process.  However, if you do not provide the information, the Company may not be able to process your application properly or at all. For example, if we require a credit check or references for the role and you fail to provide relevant details, we will not be able to take your application further.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.