LHV CANDIDATE PRIVACY NOTICE
1. INTRODUCTION AND SCOPE
We, LHV Bank Limited, with our registered office at 1 Angel Court, London, EC2R 7HJ are the relevant data controller responsible for your personal data. We are registered with the Information Commissioner's Office. This Candidate Privacy Notice explains how we and our Group companies collect, use, and protect your personal data during the course of the application and recruitment process.
This Notice applies to all job applicants located in the UK.
You should read this privacy notice carefully. If you have a question about the contents, please e-mail us at recruitment@lhv.com, or write to us at LHV, One Angel Court, London, EC2R 7HJ, or call us on +44 20 3005 0150.
If you want to contact our Data Protection Officer (the “DPO”), email us at dataprotection@lhv.com
2. WHAT PERSONAL DATA DO WE COLLECT?
Personal data means information which identifies you and relates to you as an individual. As your prospective employer, we will collect, use and store your personal data for a wide variety of reasons in connection with the application and recruitment process. We have set out below the main categories of candidate personal data which we process in connection with our recruiting activities on a day to day basis:
• personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address);
• work history and other relevant experience including information contained in your CV, cover letter or job application form;
• education information including degrees awarded, transcripts and other information provided in support of the job application;
• compensation history;
• information collected during phone screenings and interviews;
• information gathered during psychometric assessments, including reports generated from your responses, including insights into personality traits, cognitive abilities, and behavioural preferences;
• details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits;
• reference information and information received from background checks (where applicable) including information provided by third parties;
• information related to previous applications to us or previous employment history with us;
• documents evidencing your right to work (including information about your immigration status where relevant);
• date of birth;
• gender; and
• information gathered through our monitoring of our IT systems, building access records and CCTV recording in relation to your communications with us and attendance at our premises.
The majority of the personal data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal data may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.
The list set out above is not exhaustive, and there may be other personal data which LHV Bank Limited collects, stores and uses in the context of the application and recruitment process. We will update this Notice from time to time to reflect any notable changes in the categories of personal data which it processes.
The majority of the personal data which we process will be collected directly from you. However, your personal data may also be provided to us by third parties, such as recruitment or executive search agencies, third party assessment providers, credit reference agencies, professional networking sites or other public sources such as LinkedIn, former employers, official bodies (such as regulators or the Disclosure and Barring Service) and/or medical professionals.
3. REFERENCES AND VETTING
We may need to carry out background checks in relation to the following as applicable:
• Credit references/financial check;
• Professional registrations/memberships and/or qualifications check;
• Directors Search;
• Sanctions File check;
• Regulatory check;
• Right to work and immigration status check; and
• References from previous employers.
As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:
• former employers in order to verify your previous employment history;
• universities and/or other establishments for higher education that you attended in order to verify your education history;
• credit reference agencies; and
• regulatory and/or Government or public bodies.
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment or engagement with us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
4. HOW WE USE YOUR PERSONAL DATA
LHV Bank Limited uses your personal data for a variety of purposes in order to take steps necessary to enter into an employment contract with you, to comply with our legal obligations or otherwise in pursuit of our legitimate business interests . We have set out below the main purposes for which candidate personal data is processed:
• to identify and evaluate job applicants, including psychometric testing, assessing skills, qualifications and experience;
• verifying candidate information and carrying out employment, background and reference checks, where applicable and in order to prevent fraud;
• communicating with you about the recruitment process and your application;
• to comply with our legal, regulatory, or other corporate governance requirements; and
• for the purposes of conducting data analytics to review and better understand the operation of our recruitment processes.
In addition to using your personal data to consider you for the role you applied for, we will retain and process your personal data to inform you about and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your HR contact.
Again, this list is not exhaustive and we may undertake additional processing of personal data in line with the purposes set out above. LHV Bank Limited will update this Notice from time to time to reflect any notable changes in the purposes for which its processes your personal data.
5. WHAT SPECIAL CATEGORIES OF PERSONAL DATA DO WE PROCESS?
Certain categories of data are considered "special categories of personal data" and are subject to additional safeguards. We may need to process special category data as part of the application and recruitment process .
We limit the special categories of personal data which we process as follows:
• Health Information
We may process information about a candidate's physical or mental health in compliance with our obligations owed to disabled employees and to consider whether we need to provide adjustments during the recruitment process.
We will always treat information about health as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
If a candidate is successful, any health information processed as part of the recruitment process that is relevant to our compliance with our obligations in connection with employment will be retained and processed in accordance with the Employee and Contractor Privacy Notice.
If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal data within 12 months of their rejection.
• Criminal Record Information
Given the nature of our business, we ask successful candidates who have accepted a conditional offer of employment to disclose their criminal record history and we carry out criminal record checks as part of our background vetting process and in compliance with our obligations in connection with employment.
We will always treat criminal record history as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure.
Criminal record information will be deleted once the recruitment process has been completed, subject to any exceptional circumstances and/or to comply with particular laws or regulations. Criminal record information will typically be retained for a maximum of 6 months, although the outcome of any check will remain on the employee's record.
• Equal Opportunities Monitoring
LHV Bank Limited is committed to providing equal opportunities for employment and progression to all of its employees and from time to time it will process information relating to ethnic origin, race, nationality, sexual orientation and disability, alongside information relating to gender and age, for the purposes of equal opportunities monitoring.
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, this monitoring will always take place in accordance with appropriate safeguards as required under applicable law, including:
o the provision of information relating to ethnic origin, race, nationality, sexual orientation and disability for the purposes of monitoring will be voluntary and processed for this purpose only with your consent;
o wherever possible, the monitoring will be conducted on the basis of using anonymised data so individual candidates cannot be identified;
o the information processed for monitoring purposes will be maintained separately from general management and HR records.
6. WHEN DO WE SHARE YOUR PERSONAL DATA?
We will share personal data with other parties only in limited circumstances in order to take steps necessary to enter into the employment contract or where necessary to comply with a legal obligation, or otherwise in pursuit of our legitimate business interests as follows:
• Recruitment or executive search agencies that assist with the recruitment process;
• Other companies in the LHV group, to oversee recruitment / employment terms;
• Background vetting specialists that assist with checks relating to matters such as references, education history, qualifications, identity, credit status, regulatory status & registrations ,Sanctions checks and DBS checks;
• Recruitment software service providers, including Greenhouse Software and HR System (HiBob);
• Psychometric assessment providers, including Predictive Index (https://www.predictiveindex.com/privacy/) and SHL Group Limited;
• Training provider (SkillCast);
• Benefits broker and third-party providers such as Private Health Insurance, Life Assurance;
• Pensions provider;
• Outsourced payroll provider;
• UK visa sponsorship management system;
• Occupational health services providers;
• Cloud computing power, storage and software providers, including AWS and Google Cloud, which are used during the course of collating and storing the types of personal data referred to in this Notice;
• Your referees, if your application proceeds and we make you a conditional offer Regulators such as the Prudential Regulation Authority and the Financial Conduct Authority;
• HMRC and/or any other applicable government body; and
• Accountants, lawyers and other professional advisors.
In all cases other than in relation to Government and regulatory bodies, the personal data is shared under the terms of a written agreement between LHV Bank Limited and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.
7. WHERE WE STORE OR SEND YOUR DATA
We store the data we collect from you in the UK and the European Economic Area (the “EEA”). If we transfer the data we collect from you to organisations outside of the EEA, we ensure that your data is protected as follows:
- The European Commission has determined that the country offers an adequate level of data protection; or
- We have agreed to the European Commission’s standard contractual clauses on data protection with the relevant organisation.
Sometimes, third parties acting on our behalf may need to transfer personal data outside of the UK. We will take steps to ensure that third parties have put in place appropriate safeguards to protect your personal data if it is transferred outside of the UK (including in the US). This might include checks to ensure that data is transferred to countries that are considered to provide adequate levels of protection, or that there are appropriate contractual terms and security measures in place.
8. FOR HOW LONG WILL YOUR PERSONAL DATA BE RETAINED?
Our policy is to retain personal data only for as long as needed to fulfil the purposes for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
• If your application is unsuccessful, we will typically retain personal data collected during the recruitment process for a maximum period of 12 months from the end of the process subject to any exceptional circumstances and/or to comply with particular laws or regulations.
• We will typically retain personal data held in archived e-mails or other electronic files for 12 months.
If you are offered and accept employment or work with us, the personal data collected during the application and recruitment process will become part of your employment record and we may use it in connection with your employment or engagement. From the start of your employment or engagement with LHV, the processing of your personal data will be governed by our Employee and Contractor Privacy Notice. That Notice explains in more detail how we collect, use and protect your personal data throughout your employment and after your employment ends. A copy of the Employee and Contractor Privacy Notice will be available to you when you join LHV Bank Limited.
9. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
We will always seek to process your personal data in accordance with its obligations and your rights.
You will not be subject to hiring decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format. If you have any questions about these rights, please contact the Data Protection Officer using the details set out below.
You have a separate right of access to your personal data processed by LHV Bank Limited. You may be asked for information to confirm your identity and/or to assist us to locate the data you are seeking as part of our response to your request. If you wish to exercise your right of access you should set out your request in writing to your Data Protection Officer using the details set out below.
Finally, you have the right to raise any concerns about how your personal data is being processed with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/make-a-complaint/.
10. DATA SECURITY
We have implemented appropriate technical and organisational measures to protect your personal data against accidental loss, alteration, unauthorised disclosure, or access. These measures include secure access controls, encryption, firewalls, regular security testing, and employee training.
11. CONTACT DETAILS
We have appointed a Data Protection Officer to oversee compliance with this privacy notice. The contact details for your Data Protection Officer are set out below:
dataprotection@lhv.com
If you would like further information about the matters set out in this privacy notice, please contact the recruitment team and/or the Data Protection Officer.
12. UPDATES
We may update this Notice from time to time to reflect changes in how we process personal data or changes in law.
