Candidate Privacy Notice

We need to collect and use certain information about you so that we can manage our relationship with you. Some information we collect and use will be personal data.

Newton Europe Limited is a "data controller". This means that we decide how we hold and use personal information about you.

We think that it is important to be transparent about how we collect and use your personal data and are committed to protecting the privacy and security of the information we hold about you. This privacy notice provides more information about how we do this and provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

This notice applies to all prospective Newton employees, workers and contractors. We may update it at any time.

Data protection principles

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we 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 we have told you about; and
• kept securely.

What personal data do we collect?

We will collect, store and use a range of personal data about you. This includes the following:

• the information you have provided to us in your curriculum vitae and covering letter;
• the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;
• test results for tests included as part of the recruitment process;
• your video interview;
• any information you provide to us during an interview.

We may also collect, store and use the following types of more sensitive personal information:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions/affiliation/political party membership;
• information about your health, including any medical condition, health and sickness records; and
• information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates in a variety of ways. For example, from:

• you directly. For example, during interviews, meetings or assessments;
• forms or other correspondence provided by you. For example, application forms, your CV, or other forms completed during the recruitment process;
• your identity documents, such as your passport and/or driving licence.

We may also collect personal data about you from third parties, such as:

• your named referees;
• recruitment agencies and other bodies, for example High Fliers Publications Limited who compile the Times Top 100 Graduate Employers list and the Cambridge class list;
• the Disclosure and Barring Service in respect of criminal convictions;
• background check providers;
• credit reference agencies (as permitted by law); and
• publicly accessible data from third parties, including LinkedIn and Facebook.

Why do we need to process your personal data

We will need to collect, store and use personal data about you for a number of reasons:

• to perform our obligations under your contract of employment. For example, we need to process your personal data to pay you your salary and provide your benefits
• to ensure that we comply with our legal obligations. For example, we are required to check an employee's entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable you to take holiday
• to pursue legitimate interests of our own, or those of third parties.strong> When we do this, we always make sure that your fundamental interests and rights do not override those interests and
• because you have given your consent for us to do so.

The examples given below do not form an exhaustive list of purposes for which your personal data will be processed, and we reserve the right to add to them at any time.

Situations in which we will use your personal data

The situations in which we will process your personal data are listed below:

To comply with our legal obligations, including:

• checking you are legally entitled to work in the UK;
• dealing with legal disputes involving you, or other candidates, employees, workers and contractors;
• ascertaining your fitness to work;
• complying with health and safety obligations;
• complying with our obligations to notify law enforcement about criminal activity or convictions;
• complying with our obligation to make reasonable adjustments for employees, workers and contractors who have a disability; and
• to prevent fraud.

To pursue legitimate interests of our own, or those of third parties, including:

• assessing your skills, qualifications, and suitability for the role;
• carrying out background and reference checks, where applicable;
• communicating with you about the recruitment process;
• keeping records related to our hiring processes.

In each of the above cases, the legitimate interest is to allow candidates to apply for a role at Newton and to ensure that we employ suitable candidates.

Special categories of personal data and criminal convictions

”Special categories” of personal data require higher levels of protection.

We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances:

• where we need to carry out our legal obligations; and
• where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
• where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We will use your particularly sensitive personal information in the following ways:

• we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview;
• we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• We may also use information relating to criminal convictions where the law allows us to do so. We may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

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), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Who has access to your personal data?

Your information will be shared internally, including with HR, recruitment and finance in each case if and where access to the data is necessary for performance of their roles.

We may also share your personal data externally with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. For example, we may share your personal data with third parties in order to:

• administer our recruitment process. For example, administering the application process through our third-party provider World Careers Network plc;
• obtain pre-employment references from other employers or referees;
• obtain employment background checks from third-party providers;
• obtain necessary criminal records checks from the Disclosure and Barring Service; and
• obtain security clearance for you (if applicable).

Where we share your personal data with third parties, we require that they respect the security of your data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

How do we protect your personal data?

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

We have also put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We 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 we are legally required to do so.

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long do we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After this period, we will securely destroy your personal information.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal data in accordance with our retention policy.

We may retain your personal information on file on the basis that a further opportunity may arise in future and we may wish to consider you for that. We will only do this if you have given your explicit consent for us to retain your details for this purpose as part of the recruitment process.

What are your rights?

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 we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we 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 we 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• 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 we transfer a copy of your personal information to another party, please contact HR in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

During the recruitment process, you may be subject to automated decision making in the marking of your test scores.

Where you are subject to automated decision making, you will be expressly notified in advance. In these cases, you also have the right to request a reconsideration of the result of the automated decision making by submitting a reconsideration request to graduates@newtoneurope.com.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.