In this notice, the “Company” means [E D & F Man Holdings Limited, and any subsidiary or affiliate], being the entities in receipt of your job application.
E D & F Man Holdings Limited is registered in the UK and its registered address is at 3 London Bridge Street, London, SE1 9SG.
As part of any recruitment process, the Company collects and processes personal data relating to job applicants. 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?
Information that you provide to the Company
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the country where you applied for the role., including your nationality; and
- any other details you provide in support of your Application, including (but not limited to) information contained in your CV and/or covering email and your reasons for applying to the Company.
The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests. In the event that you include information in your application (such as your CV) which is not required by the Company and/or not requested specifically, such data will nevertheless be processed by the Company in accordance with this notice.
Information the Company obtains from other sources:
- personal data that the Company obtains from third party recruitment agents. This data might include your name and contact details and other information included in CVs or resumes; and
- personal data that the Company obtains from third parties to verify the information that you provide to us as part of your application, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The Company will seek verification information from third parties only once a job offer to you has been made and will inform you that it is doing so.
The Company does not collect information about you save as above.
Why does the Company process personal data?
Subject to applicable law your personal data may be stored and processed by the Company in the following ways and for the following purposes:
- to consider your job application to assess and confirm your suitability for employment (including, in some cases, verifying your qualifications, education and references with those third parties you name);
- to make reasonable adjustments in the recruitment process for disability;
- to take steps to enter into a contract with you ;
- to maintain consistent practices and procedures with respect to the collection, use, disclosure, transfer and processing of personal data across the Company network worldwide. These practices and procedures include the effective recording, management and administration of personal data;
- to ensure that it is complying with its legal and regulatory obligations;
- to defend legal claims; and
- the prevention and detection of crime or fraud, subject to local law.
The Company is entitled to use your personal data in these ways because:
- the Company needs to consider you for a position that will require you to enter into a contract with the Company;
- the Company must discharge legal and regulatory obligations;
- the Company may need to establish, exercise or defend its legal rights or for the purpose of legal proceedings; and
- the Company may have a legitimate interest in processing personal data before commencing the employment relationship, such as:
- allowing the Company to effectively assess your skills, qualifications and/or the strength and merits of your application and your suitability for the role
- allowing us to effectively verify your information;
- allowing the Company to effectively and efficiently administer and manage the operation of its business (i.e. recruitment);
- ensuring a consistent approach to recruitment
- allowing the Company to contact you in relation to the recruitment process; and
- maintaining compliance with internal policies and procedures.
Some special categories of personal data, such as information about health or medical conditions, are processed to discharge legal obligations in relation to job applicants with disabilities.
The Company will not use your data for any purpose other than the recruitment exercise for which you have applied. The company may also use your data to be considered for other roles if you have provided your consent to this.
Who has access to data?
Your information may be shared internally within the Company for the purposes of the recruitment exercise. This includes 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.
If your application for employment is successful and the Company makes you an offer of employment, the Company will contact former employers to obtain references for you, employment background check providers to obtain necessary background checks and any relevant Agencies or Services to obtain necessary criminal records checks. Such checks may require the Company to provide sufficient data in order to identify you.
As a global company, many of our employment activities involve business leaders and managers who are located outside the European Economic Area (EEA). Therefore, your information may be transferred to countries outside the EEA.
Where the Company transfers your personal information outside the EEA, the Company will ensure that it is protected in a manner that is consistent with how your personal information will be protected by the Company within the EEA. This can be done in a number of ways, for instance:
- the country that the Company send the information to might be approved by the European Commission as offering a sufficient level of protection;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information; or
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.
In other circumstances the law may permit the Company to otherwise transfer your personal information outside the EEA. In all cases, however, the Company will ensure that any transfer of your personal information is compliant with data protection law.
How does the Company protect data?
The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does the Company keep data?
How long we hold your personal data for will vary. The retention period will be determined by various criteria including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The criteria that determine the retention periods for which your data will be held during your employment will be provided to you in a new privacy notice.
In some instances we may ask you if you would like us to keep your information on file so that we can consider you for other roles and future opportunities at E D & F Man. If you decide to join our talent pool and then subsequently no longer wish to be considered for other roles or opportunities, you can contact us at any time to withdraw your consent to us keeping your information. Please note that the Company may still be entitled to process your personal data if the Company has a legitimate reason (other than consent) for doing so.
As a data subject, you have a number of legal rights in relation to the personal data that the Company holds about you. You have the right:
- to obtain information regarding the processing of your personal data and to access a copy of your personal data;
- to withdraw your consent to our processing of your personal data at any time. Please note, however, that the Company may still be entitled to process your personal data if the Company has another legitimate reason (other than consent) for doing so;
- to request that the Company rectifies your personal data where it is incorrect or incomplete;
- in some circumstances, to receive some personal data in a structured, commonly used and machine-readable format and/or request that the Company transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to the Company;
- in some circumstances, to request that the Company delete your personal data;
- to object to, and the right to request that the Company restrict processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask the Company to restrict, our processing of your personal data but the Company is legally entitled to continue processing your personal data and / or to refuse that request; and
- to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by the Company.
If you would like to exercise any of these rights, you can do this via our applicant tracking system. If you have not applied for a role via our applicant tracking system, you can contact the Human Resources team at the ED&F Man office where you applied for a role.
You can find out more information about your rights by contacting the Information Commissioner’s Office, contact details for which can be found at www.ico.org.uk. Alternatively, you can contact the equivalent authority in the country where you are applying for a role.
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.
In some cases, part of the Company’s recruitment processes may be based solely on automated decision-making. The Company will inform you separately if any part of your recruitment process is based partially or solely on automated decision-making.
If part of your recruitment process is based on automated decision-making, you will be provided with additional, specific information in relation to the automated decision such as the logic involved in the automated decision-making process and the possible consequences for you. The information and rights set out in this notice will still apply to you.