UK Candidate Data Protection Notice
Last Updated: May 2024
The purpose of this notice is to make you aware of the basis on which we, being BMC UK Subadvisor Support Limited, its sister company Battery Management Corp. (“BMC”), and other entities advised or affiliated with BMC (collectively referred to as “Battery”, “we“, “us” or “our”), collect personal data about you, or that you provide to us (either directly or indirectly), and how it will be processed by us (as a data controller).
This notice does not form part of any contract of employment or other contract to provide services and we may amend it from time to time. Any significant changes will be notified to you.
COLLECTION & CATEGORIES OF PERSONAL DATA
We will collect and process (which means doing anything with the data, such as obtaining, using, holding, amending, disclosing, deleting, destroying, storing and transferring the data in any way) personal data we receive from you, either directly or indirectly. We collect this information from (i) you; (ii) recruitment agencies; (iii) background check providers; (iv) credit reference agencies; (v) Disclosure and Barring Services or similar; (vi) referees; and (vii) publicly available sources of information.
We typically collect the following categories of personal data:
- Contact information, such as: name, nickname, email address (personal and work), mobile phone number (personal and work), home address, date of birth, gender.
- Work-related information, such as: information on previous employer/work experience, qualifications, salary information, training information, professional memberships, CVs, academic history.
- Background check information, such as: educational qualifications, reference checks, credit & financial history.
- Interview information, such as: information shared during the interview stages.
We do not always collect “special category personal data”, but we may require this for your role and/or you may offer this as part of your interactions with us. Such information may include:
- Diversity information, such as: information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Health information, such as: information about your health, including any medical condition, health and sickness records.
- Criminal conviction, such as: information about criminal convictions and offences.
PURPOSES & LAWFUL BASIS
We will process your personal data only where there is a valid lawful basis. In general, this will be where it is necessary: (i) for us to take preparatory steps to enter into a “contract” with you; (ii) for compliance with a “legal and/or regulatory obligation” as an employer; (iii) for our “legitimate interests” or the legitimate interests of others; or (iv) where you have volunteered the information and/or specifically provided “consent”.
We will only process Special Category Personal Data where a further condition is also met. Usually this will mean that the processing is legally required or with your explicit consent.
| Purposes | Categories of Personal Data | Lawful Basis |
| To assess your skills, qualifications, and suitability for the role | Contact information
Work-related information Interview information |
Contract
Or Legitimate interests (so that we can assess your skills, qualifications, and suitability for the role) |
| To carry out background and reference checks, where applicable | Background check information
Criminal conviction |
Legal obligation (as a regulated entity in connection with employment)
Or, if not Legitimate interest, namely e.g. given we are a regulated business, and in a position of trust with regard to our clients, for security purposes With respect to criminal conviction information, this is processed in our legitimate interests for the reasons above and is Substantial public interest (i.e. for preventing or detecting unlawful acts) |
| To communicate with you about the recruitment process | Contact information | Legitimate interests (so that we can engage with you) |
| To keep records related to our hiring processes and for other administrative and management purposes | Contact information
Background check information Work-related information Interview information |
Legitimate interests (so that we have information available in relation to the recruitment process)
With respect to criminal conviction information, this is processed in our legitimate interests for the reasons above and is Substantial public interest (i.e. for preventing or detecting unlawful acts) |
| To provide accommodations/adjustments to your during recruitment | Health information | Consent
Or Legal obligation (Employment-related legal obligations e.g. health and safety, occupational health, disability discrimination laws) |
| For equal opportunity monitoring and reporting | Diversity Information | Consent
Or Legitimate interest, and (i) necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified in relation to that category with a view to enabling such equality to be promoted or maintained; and/or (ii) necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by employment/social security or social protection – related legal obligations. |
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Failure to provide us with the relevant personal data, in cases where you are legally or contractually required to provide it, may result in our being unable to hold up our end of the contract or meet legal requirements. For example, if you do not provide us with your bank details, we will not be able to pay you.
We do not anticipate that any processing activities relating to your personal data will involve any automated decision-making (including profiling). There is always human involvement.
DATA RETENTION
We will endeavour not to keep your personal data in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes. This means that we will endeavour to destroy or erase personal data from our systems or anonymise it when it has reached this retention period. If you do join Battery, retention of your personal data will be subject to internal personnel retention periods.
ACCURACY OF DATA
We will endeavour to keep the Personal Data we store about you reasonably accurate and up to date by enabling you to correct it by request. Please notify us if your personal details change or if you become aware of any inaccuracies in the Personal Data we hold about you.
PROCESSING IN LINE WITH YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to request us to:
- provide access to personal data we hold about you;
- rectify any inaccuracies in your personal data that we hold;
- delete any of your personal data that we no longer have a legitimate interest to process;
- where we process your personal data based on your consent, withdraw your consent so that we stop that particular processing;
- port your personal data and to request the transmission of such data to another organization;
- object to any processing of your personal data based on our “legitimate interests” unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; or
- restrict how we process your personal data whilst a data protection complaint is being investigated.
If you wish to exercise one of these rights, you must do so in writing to hr@battery.com.
You also have the right to lodge a complaint with the UK’s data supervisory authority, the ICO. However, we would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
DISCLOSURE AND SHARING OF PERSONAL INFORMATION
We may share Personal Data we hold with any entity affiliated with or related to Battery and relevant personnel.
We may also disclose personal data we hold to certain third parties, including legal advisers, experts, translators, law enforcement authorities, regulators, recruitment agencies, background check agencies, potential referees, government authorities, benefit administrators, payroll providers, accountants, adverse parties who have a legal right to receive such information and their counsel and experts. We will disclose this data:
- in order to comply with legal governmental and/or regulatory processes or obligations, conduct internal reviews, and address potential risk or harm to the Firm and/or our personnel;
- for background and reference check purposes;
- to enforce or apply any contract with you or other agreements;
- to protect our rights, our property or the safety of our personnel or others; and
- in order for authorized third party providers to conduct reference checks and/or background checks or for the purposes of recruitment.
In the unlikely event that we sell or buy any business or assets, we may disclose personal data we hold to the prospective seller or buyer of such business or assets. In addition, if all or substantially all of our assets are acquired by a third party, the personal data we hold will be one of the transferred assets.
We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this notice and applicable laws.
TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE UK
Personal data may be transferred outside of the UK with any entity affiliated with or related to Battery or to other third party service providers as set out above, provided that certain conditions as set out in the applicable legislation are complied with.
In that regard, we ensure a similar degree of protection is afforded to it by ensuring that there are appropriate safeguards that comply with applicable data protection laws. This means typically we either only transfer personal data to a country that has been deemed to provide an adequate level of protection for personal data by applicable data protection authorities or we may use specific contracts approved by applicable data protection authorities which give your personal data the same protection it has in the UK (where and as applicable).
QUESTIONS
Please contact hr@battery.com if you have any questions in relation to the above.