Candidate Privacy Notice

Candidate Privacy Notice​
This privacy statement applies to Altery*, and the entities we own or control (“Altery”, “we”, “us” or “our”). Altery respects your privacy and is committed to protecting your personal data. This privacy policy explains how and why we use your personal data. The following privacy notice explains what information we collect about you, how we use it, and who we share it with. The document also explains your rights and who you can contact for more information. If you have any questions concerning our use of your personal information or this Notice, please contact our Data Protection Officer at [email protected].
1. What sort of personal data do we collect?
We collect personal data about you during the recruitment process. Additionally, we obtain personal information about you from our service providers (including third party recruitment agencies (which may contain details about your qualifications and experience) and providers who assist us with candidate screening (which may include personal data related to special categories). A full list of personal data we collect can be found below. As part of our screening process, we may also check publicly available sources, such as LinkedIn or other similar sites, for information regarding your skills, experience, and qualifications.
2. Sources of information
This personal information is either:
● Provided by you;
● Obtained from third parties (normally through the application and recruitment process);
● Created by us in the course of job-related activities during your employment/engagement with us. Personal information may be obtained from the following third parties: former employers, employment agencies, other background check agencies.
3. How do we use your personal information
We use your personal information for:
● Human resources management
● Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion
● Making decisions about salary and other benefits
● Making decisions about contractual benefits to provide to you
● Assessing training needs
● Preventing Fraud
4. What are the legal basis for using your personal information
The legal basis on which we will use your personal information is because:
● To carry out checks in relation to your right to work in the UK
● Making reasonable adjustments for disabled employees
5. When do we have "legitimate interests"?
We use your personal information where this is necessary for our legitimate interests (or those of a third party) to:
● Protect the assets, employees, clients and other stakeholders and partners of the company
● Be able to contact you or your family in the case of an emergency.
● Check you are legally entitled to work in the country where you are based.
● Manage performance and promotion processes, as well as training and development requirements.
● Deal with HR and Health & Safety matters, in which we may take legal or other professional advice.
● Prevent fraud, including IT workspace monitoring.

If you would like further information on our legitimate interests as applied to your personal information, please contact the Data Protection Officer.
6. How we use Special category data
Special category data must be treated with extra care under data protection law. The categories of special category data include biometric data (physical, physiological, or behavioural characteristics about you), health data, criminal convictions, and any religious or political information you provide. We’ll only use special category data for the following purposes:
● detecting and preventing financial crime,
● verifying your identity through the use of biometric data; and
● making our services accessible to customers.
● In addition, we won't process special categories of information unless we've received your explicit consent or are permitted to do so under a limited set of conditions.
7. The lawful basis for the use of your special category personal information
The lawful basis on which we will use your special category personal information is because:
● In order to establish, exercise, or defend legal claims, it is essential.
● Our obligations and employment rights are subject to authorisation from the European Union or the UK.
● It is necessary for substantial public interests, such as monitoring equal opportunities.
● Exceptionally, where it is necessary for vital interests relating to you or another person (for example, avoiding the severe risk of harm to you or others) where you are physically or legally incapable of giving consent.
● You have given your explicit consent to the processing of your special category personal information. Please note that your consent can be withdrawn at any time. However, this may affect the provision of certain benefits to you where the processing of special category personal information is necessary for the benefit (e.g. private health insurance).
8. Personal Information that we share
We use and share your personal information with employees and other third parties in the course of running our business. These third parties include:
● Pre-employment screening providers
● Banks and payroll providers
● IT administrators
● Training providers
● Auditors
● Building security providers
● Consultants and other professional advisers

We will also share your personal information with providers of employee benefits, future and prospective employers, regulators such as the UK Financial Conduct Authority, and other competent authorities (e.g. tax authorities), courts and otherwise as required by law. We will never allow third parties to use your personal data to market to you in their own name unless we have your consent. We will share your contact or other relevant personal information with our customers, for example, when appointing you as our relationship manager, or otherwise in the course of providing services to them. We will share personal information with companies, organisations or individuals outside our group companies if we have a belief in good faith that disclosure of the personal information is reasonably necessary to:

● Meet any legal requirements
● Enforce your employment agreement with us, including investigation of potential violations
● Detect, prevent or otherwise address fraud, security or technical issues
● Provide potential acquirers or purchasers with personal information concerning the disposal of our or our group companies' business or assets
● Provide other group companies with your personal information in the context of a restructuring of the business
● Protect against harm to the rights, property or safety of us or our group of companies, our employees, contractors, customers or the public, as required or permitted by law.
9. Retaining your personal information
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including the purposes of satisfying any legal, accounting or reporting requirements.
In general terms, this means that we will retain your personal information for the duration of your employment/engagement with us and for the length of any applicable limitation period for claims which might be brought against us later (e.g. six years in the UK). There are also certain types of personal information, such as tax records, which require to be retained for a certain period by law. If you require more specific information on these timelines depending on the country you are based in than please contact the Data Protection Officer.
We will retain information that you provide that helps us to:

● Comply with legal and regulatory requirements, such as anti-money laundering laws and laws requiring us to keep records of transactions we've participated in (loan repayments, investor payments).
● Legally establish, exercise, and defend claims
● Fraud prevention and detection
● ensure we don’t send marketing to people who have opted out
● maintain business records for analysis and audit purposes
10. How do we secure your personal information
We protect the privacy of your personal information by following strict security procedures when storing, using, and distributing it.
11. Where do we store your personal data
Your data will be stored in a range of different places, including on your application record, and on other IT systems (including email). These details will be stored in the cloud safely.
12. Your Rights
You have a right to access, correct, erase, object to, restrict and transfer your personal information under certain circumstances as well as the right to withdraw consent. To exercise any of these rights, please contact the Data Protection Officer in writing at [email protected].
If you are unhappy with the way in which we have handled your personal data, you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at
13. Consequences of processing your personal data
If we or the screening agency establish that you may pose a fraud or money laundering risk, we may not be able to offer you employment. If you have any questions about this, please contact us using the details above
14. Personal information not provided has the following consequences:
You don't have to provide us with your personal data, however you must provide us with information partly to comply with the law (for example, so we can verify your identity), and partly, so we can offer you work.
15. Background
Altery is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter - GDPR), and the UK Data Protection Act 2018.
16. Collected information
Personal information relating to you:
(1) title, name, date of birth, age, gender, home address, personal email address, telephone number, driving licence number, passport number, and where applicable, national tax ID, social security number, National Registration Identity Card (NRIC), (2) resumé/CVs which will include information on your education and training details, such as qualifications, academic records, schools, training record, professional expertise, (3) personnel records, which include offer letters, recommendations, policy acknowledgements, employment agreements, promotion and transfer records, employee licences and certifications, termination ad resignation letters, exit interview notes and severance agreements, performance evaluations and reviews, leave requests and absence records, disciplinary and grievance and training records and professional memberships, (4) information provided as part of the recruitment process, (5) employment details, such as employment status, job title(s) and description, employee ID, employee type, and whether full time or part-time, work location, hire/start date, termination date, individual photo, and organisational details such as name of company, work phone number and email, intranet user log in, department and supervisor details, (6) financial information, such as salary and compensation history, benefits (including enrolment and application forms, reports on accruals and years of service, documentation summarising enrolment and participation on benefit programs, general employee communications related to benefits), pay, travel expenses, payment information, bank account information, bonus targets, pensions information, and corporate credit card usage, and (7) records generated by and in relation to investigations of misconduct allegations or for the general purpose of collecting facts or other information
Personal information relating to your family:
(1) emergency contact person(s) and their contact details, (2) marital status, number and identity of dependents and spouse (if any) where necessary for the purpose of any employment benefits, and (3) beneficiary information, as regards health insurance and other benefits for employees and their families.
Personal information relating to your usage of our information and communications systems, including records of your use of our IT systems, e.g. emails, internet systems, computers, laptops (including via remote access), telephone and mobile devices.
Background check the personal information, such as driving records and criminal offences' data.
Special category personal information:
(1) racial and ethnic origin and information relating to disabilities, religious beliefs or sexual orientation for equal opportunities monitoring (where relevant), (2) physical or mental health or condition (e.g. health data, health and attendance records, medical exams and records resulting from sickness absence or injuries at work and accidents as well as employee medical records required by law or governmental agencies, and immigration/naturalisation records for employees and workers where this discloses racial/ethnic origin information.
* Altery is a registered trademark of Altery Ltd, who’s an Electronic Money Institution (EMI) that is authorised and regulated in the United Kingdom by the Financial Conduct Authority (FCA), our FCA firm’s reference number is 901037. Altery Ltd will protect your funds through the safeguarding method and not the Financial Services Compensation Scheme (FSCS).