EQ Global Recruitment Privacy Notice

This Privacy Notice applies to candidates during the application, recruitment, and employment screening process for all roles at EQ.

1. Who we are

Equiniti Services Limited acts as a Data Controller for your personal data processed in connection with your online portal account for recruitment. This means that Equiniti Services Limited is responsible for deciding how and why we hold and use personal data about you in relation to your access and use of your online portal account. Equiniti Services Limited registration number with the Information Commissioner’s Office (ICO) is Z9180809, and our address is Highdown House, Yeoman Way, Worthing, BN99 3HH. The specific EQ business (company) is classified as your “Data Controller” in connection with the application, recruitment, and employment screening process.  

2. What this Privacy Notice covers

This Privacy Notice explains how we protect your personal information when you log into our online portal account and the  information gathered  via  our  website  during  the  online recruitment application, registration process as well as during further recruitment processes, including face to face selection assessments, employment screening and vetting.

Our websites may contain links to other websites run by other organisations, or other Equiniti companies. This Privacy Notice applies only to EQ’s recruitment websites, where the link appears. When you are on another website, we encourage you to read their privacy statements as it will take precedence over this Policy.  

3. How your personal data is collected

Some data will be collected automatically when you use our website. Other data will only be collected if you voluntarily submit it, such as your CV and application.   We may collect some or all of the following data as set out below.

• Information you provide - as part of setting up your online portal account as well as via the application and recruitment process you provide us with your application and relevant personal details.
• Information provided by third parties - as part of the employment screening process, we collect information from other sources about you.   We collect this from third-party suppliers of information (to check or verify the accuracy of information provided by you) including public bodies, and other publicly available sources of information.
• Automatically collected information – such as when you visit our website, we automatically collect information about your computer hardware and software such as your IP address, browser type, referring website addresses, pages visited, and links clicked.

4. Why we collect your personal data

We will only use your personal information in accordance with relevant legislation and only as permissible under applicable law. Most commonly, we will use your personal information in the following circumstances:

• Where we need to take steps, at your request, to enter into a contract with you.
• This forms part of the recruitment and selection process and the management and operation of your online account with us.   It also includes assessing candidate applications, face to face selection assessments, employment screening and vetting if your application is successful and this can include identification and verification checks, criminal record checks, credit checks, Politically Exposed Person (PEP) and sanction checks, Fraud checks, Reference and employment checks and any other checks that are necessary for the role you have been offered.  Equiniti may also check publicly available sources such as LinkedIn or similar sites with professional purposes for information regarding your skills, experience or qualifications.
• Where we need to comply with a legal obligation.
• This includes for example for checking that we may legally employ you in the country you have applied to work in and ensuring you are fit and proper for the role and in accordance with any local requirements.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• This can include for example ensuring network and information security, identifying service improvements and conducting Equal Opportunities monitoring.
• When we have your consent to process your personal data.

Special category personal information requires higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations or exercise rights in connection with your application.
• Where it is needed in the public interest, on the basis of other applicable legislation such as for equal opportunities monitoring and regulatory references including detecting unlawful acts, preventing fraud and financial crime checks.

We can confirm that no automated decisions are made about you as part of the Equiniti selection and application process.

5. How long we hold your personal data

We will only hold your personal data for a period of six months from the date you were last unsuccessful in your application unless you are successful in your application. CV’s submitted via email will be deleted, they must be uploaded to the Workday portal as part of an application process. 

You have a right to request that your personal data be deleted in accordance with your right of erasure (see "Your rights" section below).   Even if we delete your personal data, we reserve the right to maintain a copy for legal purposes, but in such event, we will do so only if necessary to fulfil those purposes.

6. Who your personal data may be shared with

The personal data we hold about you is confidential, and we will only share your personal data to enable us to manage your application as part of selection and recruitment processing activities or when we are legally obliged to do so.     When we share your personal data with others, we put contractual arrangements and / or security mechanisms in place, as appropriate, to protect your personal data and to comply with our data protection, confidentiality, and security standards. Your personal data may be shared as follows:

• Within the Equiniti Group of Companies – as part of reviewing your CV and processing your application.
• Third parties that assist us with employment screening services – such as Credit reference agencies, Fraud prevention agencies, current and previous employers; professional bodies and educational institutions; Public bodies and law enforcement agencies.
• Third parties that assist us with managing our website and your online portal account.
• Our Clients - If further vetting and screening requirements are specifically required for the role and as permissible under applicable law.
• Law enforcement or other government/regulatory agencies/other third parties occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or respond to a court order.   We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

7. Overseas processing

Your application will be hosted by Equiniti Services Limited which is based in the UK. In addition, it may be reviewed, and if successful your offer will be processed by People Services, in India.  Depending upon the role you have applied for and where it is based, your personal data may be shared with parts of the EQ Group with colleagues outside of the country in which you are located. Our recruitment database is based in Eire (Ireland), which is part of the EU.

Whilst data protection laws and standards differ in countries outside of the UK and the EEA, the EQ Group works to the standard of the UK’s and EU’s Data Protection legislation and will take all reasonable steps to ensure that your data is treated as safely and securely as it would be under UK and EU Data Protection Legislation.  We will ensure adequate safeguards are in place to protect your personal data before making the transfer, these include but are not limited to, the use of legally binding contracts amongst the Equiniti Group of Companies as well as between us and our suppliers, adequacy arrangements or the use of EU approved Model Clauses with the UK Addendum and Transfer Risk Assessments. 

8. Your rights and how to exercise them

Once you have applied for a vacancy and registered your online portal account, you may access your profile update your details, or withdraw your details at any time. To do this, you can access your personal profile by using your secure login. To exercise any of your rights under Data Protection legislation contact DPO@equiniti.com or via your people services representative.

If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection Officer using the contact details below, who will investigate the matter and report back to you.

If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection supervisory authority in your country.

In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation.  They can be contacted by email:  casework@ico.org.uk, post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113.

As your personal data is processed in Eire, you also have the ability to be able to refer to the Irish Data Protection Commissioner, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland and online via https://forms.dataprotection.ie/contact.

9. Changes to this Privacy Notice

We review our use of your information regularly. In doing so, we may change what personal data we collect, how we keep it and or what we do with it. As a result, we may change this Policy from time to time to keep it relevant and up to date with changes to the law.  We encourage you to periodically review this Privacy Notice to be informed of how we are protecting your personal data.

10. Non-UK Recruitment requirements

10.1 - India

• Personal data is collected on behalf of Equiniti India (Private) Limited, part of the Equiniti group and is registered at DLF IT Park, 1/124 Mt Poonamalle High Rd, Ramapuram, Chennai, Tamil Nadu 600 089, India.
• Dependent upon the role requirements, employment screening in India can include a request of your records from District Magistrates or Police Commissioners in areas where you have lived.
• Indian applications are subject to the protections of the EU GDPR for information that is processed within EQ recruitment system. This is because the EQ recruitment system is located in Eire, an EU member state.

10.2 - Netherlands

• Personal data is collected on behalf of KYCnet B.V., EQ KYC Systems B.V or EQKYC Solutions B.V all part of the Equiniti group and registered at Donker Curtiustraat 7, Unit 117-118, 1051 JL Amsterdam, The Netherlands
• If the position you are applying for requires a certificate of good conduct, we will seek confirmation via the VOG (Verklaring Omtrent Gedrag) process.  
• The Dutch Supervisory Authority is contactable via Autoriteit Persoonsgegevens (AP), Postbus 93374, 2509 AJ DEN HAAG

10.3 - Poland

• Your personal data is collected and processed for the recruitment purposes of EQ Tek Sp. z o.o., part of the Equiniti group and is registered at ul. Wielicka 28B, 30-552 Kraków, Poland, as your Data Controller.
• If the position you are applying for requires a certificate of no criminal record, EQ Tek Sp. z o.o. will seek confirmation of a clean criminal record from the National Criminal Register in accordance with applicable law, including the Act of 12 April 2018 on rules for obtaining information on the criminal record of persons applying for employment and persons employed in financial sector entities.
• Providing information to EQ for processing based on consent or legitimate interests (in section 4 above) is voluntary. The absence of the consent or its withdrawal cannot constitute grounds for the adverse treatment of an applicant for employment and cannot give rise to any negative consequences towards an applicant. The processing of special categories of personal data applies to data provided on the initiative of the applicant only.
• Further to section 5 above, Polish applicants need to consent for EQ to retain personal information for the purposes of future recruitment. This information will be held for a period of 18 months unless consent is withdrawn.
• The Polish supervisory authority is the President of the Personal Data Protection Office, who can be contacted at Office of the President for Personal Data Protection, Urząd Ochrony Danych Osobowych, Stawki 2, 00-193 Warsaw, Poland or https://uodo.gov.pl/en.

10.4 - USA

• Personal data is collected on behalf of EQ Trust Company part of the Equiniti group and is registered at 25th Floor, 90 Park Ave, New York, NY10016, USA.
• Criminal record checks.
• American applications are subject to the protections of the EU GDPR for information that is processed within EQ recruitment system. This is because the EQ recruitment system is located in Eire, an EU member state.

11. Contact Details

If you have any further queries relating to your data privacy, please contact recruitment@equiniti.com in the first instance.

If you have any questions that remain unanswered, please contact our Data Protection Officer by email at  DPO@equiniti.com, or by post EQ, PO BOX 5243, Worthing, BN99 9FY.