Careers at Collas Crill

1 What is the purpose of this document?

This privacy notice describes how Collas Crill Group Limited, its affiliated and subsidiary companies and partnerships globally other than Collas Crill Trust Limited and its subsidiaries and Collas Crill Corporate Services Limited (collectively “Collas Crill” or the “Group”) collects and uses personal information about you in accordance with the applicable data protection legislation.

Collas Crill recognises the importance of this data and the risks related to its possession of such data. Collas Crill is committed to protecting the privacy and security of your personal information.

Collas Crill is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice.

This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2 About Collas Crill

Collas Crill Group is made up of a number of different entities, but for the purposes of recruitment, and your use of the Pinpoint recruitment platform, Collas Crill Group Limited will be the company which controls your personal data. More detail of our group is available at www.collascrill.com.

We have appointed a Group Information Officer to oversee compliance with this privacy notice for the Collas Crill Group. In each jurisdiction where we work, we have a Local Information Officer to work with the Group Information Officer.

If you have any questions about this privacy notice or how we handle your personal information, please contact your Collas Crill Local Information Officer or the Group Information Officer, contact details of whom are set out below. You have the right to make a complaint at any time to your local regulator for data protection and privacy issues. Details of the local regulators are also set out below:

Group Information Officer

Sandy Salter

+44 1481 734826

Information.Officer@collascrill.com

British Virgin Islands:

Local Information Officer: Charlotte Cloete

+1 345 914 9616

Information.Officer@collascrill.com

Regulator: N/A

Cayman:

Local Information Officer: Charlotte Cloete

+1 345 914 9616

Information.Officer@collascrill.com

Regulator: Information Commissioner

Guernsey:

Local Information Officer: Andy Le Lacheur

+44 1481 734 814

Information.Officer@collascrill.com

Regulator: Guernsey Data Protection Commissioner

Jersey

Local Information Officer: Andy Le Lacheur

+44 1481 734 814

Information.Officer@collascrill.com

Regulator: Office of the Information Commissioner

London

Local Information Officer: Andy Le Lacheur

+44 1481 734 814

Information.Officer@collascrill.com

Regulator: Information Commissioner's Office

3 About Pinpoint

Pinpoint is an online recruitment software product provided by The Infuse Group Ltd (t/a Pinpoint Software) ("Pinpoint"). We use Pinpoint to assist with the Collas Crill recruitment process. Pinpoint will process your personal information as a data processor on our behalf. Pinpoint will only process your personal data in accordance with our instructions. Any questions, comments and requests regarding Pinpoint can be addressed to tom.hacquoil@infuse.group. Future references in this privacy statement to "we", "us" and "Collas Crill" shall include Pinpoint where applicable.

4 Data protection principles

We will comply with applicable data protection law. Whilst these obligations differ between the various jurisdictions the Group operates in, Collas Crill has committed to applying the highest standards across the Group. This means that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

5 The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection (as detailed in paragraph 11).

We may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.
Marital status and dependants.
Qualifications, experience and any information relating to your employment history, skill and experience.
Copies of any documents provided when you apply for a role with Collas Crill including, but not limited to, identification documentation and correspondence exchanged between you and Collas Crill.
Details of your visits to the Collas Crill careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.

We may also collect, store and use the following "special categories" of more sensitive personal information:

Information about criminal convictions and offences.
Information about your family and personal life relevant to your potential recruitment by Collas Crill.

6 How is your personal information collected?

We collect personal information about you:

when you apply for a role with Collas Crill, be that from an online application, email, in person at an interview and/or by any other method; and
when you access our careers website.

We may also link the data you provide us with other publically available information about you that you have published on the internet (this may include social media sites such as Linkedin for example).

Using Pinpoint, we may search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.

We may sometimes collect additional information from third parties including, credit reference agencies or other background check agencies or databases.

7 How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that we receive from you with information obtained from third party data providers.
To find appropriate candidates to fill our job openings.
To help Pinpoint improve their services.

We may also leverage Pinpoint to help us select appropriate candidates for us to consider based on criteria we have identified. The Process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by Collas Crill.

8 Situations in which we will use your personal information

We need all the categories of information in the list above (see paragraph 5) primarily for the Collas Crill recruitment process and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information.

9 If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to process your application for a role with Collas Crill.

10 Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11 How we use sensitive personal information

"Special categories" sensitive personal information require 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.

Less commonly, we may process this type of information where you have already made the information public. We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

12 Do we need your consent?

We do not need your consent if we use your personal information in accordance to carry out our legal obligations or exercise specific rights under the law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

13 Information about criminal convictions

We envisage that we will hold information about criminal convictions.

Where appropriate, we will collect information about criminal convictions as part of the recruitment process, be that directly by you or by a third party agency.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary for the recruitment process or to carry out our legal obligations.

Less commonly, we may use information relating to criminal convictions where you have already made the information public.

We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.

14 Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where we have notified you of the decision and given you 21 days to request a reconsideration.
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

15 Data Storage Locations

Personal data about you that we collect and process will be stored:

On the Collas Crill internal computer systems which are located in the jurisdictions in which Collas Crill operates; and/or
at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes.

By submitting your personal data, you agree to this transfer, storing or processing.

16 Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect an equivalent degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary as a part of the recruitment process or where we have another legitimate interest in doing so. This may involve us sharing your information with:

regulators and other authorities;
Credit reference agencies;
Fraud prevention agencies;
Organisations that introduce you to us;
Market researchers;
Companies you ask us to share your data with; and
Credit card companies and direct debit operators.

If the make-up of the Collas Crill Group changes or such changes are proposed we may share your data with third parties to allow us to sell, merge or transfer aspects of our business or acquire or merge into other businesses. We will only do this if they agree to keep your data to the same standards we have set for holding your data. Following such a change other parties may use your data in line with these standards.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. Due Diligence checks are carried out by third-party service providers on behalf of Collas Crill.

How secure is my information with third-party service providers and other entities in the Collas Crill group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group, to the extent required for the recruitment process or in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

17 Transferring information outside the EU

We will transfer the personal information we collect about you to the following countries outside the EU:

British Virgin Islands; and
Cayman,

in order to perform our recruitment process in relation to you. There is not an adequacy decision by the European Commission in respect of all of those countries. This means that some countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place binding contract clauses in line with international standards to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the applicable laws on data protection. If you require further information about these protective measures, you can request it from your Local Information Officer.

17 Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

18 Data retention

For the purposes of the recruitment process we will only retain your personal information for a period of 48 months. If you accept a role with Collas Crill then your personal data will be used and retained in accordance with the terms and conditions of your employment contract, the Collas Crill Staff Hand Book and such other policies, notices or rules as are applicable to a Collas Crill employee.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Personal information about you held by Pinpoint may be manually deleted via the Manage Your Data tool.

If you have any questions regarding data retention please speak to your Local Information Officer.

19 Marketing

We may use your personal information to let you know about roles at Collas Crill we think may be of interest to you. Before doing so we may use your personal information to better understand what roles you are likely to be interested in.

If you ask us to stop using your personal information to market to you, we will do so and you can change this choice at any time.

20 Cookies

We use "cookies" on our website, these are small pieces of data that allow us to track which computers visit our website and how. To find out how, please review our cookie policy https://www.collascrill.com/cookies/.

21 Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your Local Information Officer in writing.

Personal information about you held by Pinpoint may be manually deleted via the Manage Your Data tool.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

22 Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your Local Information Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

23 Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Schedule

How Collas Crill uses client data: To consider your application in respect of a role for which you have applied.

Our basis for doing so: Collas Crill's legitimate interest. Your consent

Collas Crill's legitimate interests (where appropriate): Maintaining proper practice and efficiencies in meeting our legal and commercial obligations. Developing and growing our business

How Collas Crill uses client data: To consider your application in respect of other roles.

Our basis for doing so: Collas Crill's legitimate interest. Your consent.

Collas Crill's legitimate interests (where appropriate): Maintaining proper practice and efficiencies in meeting our legal and commercial obligations. Developing and growing our business.

How Collas Crill uses client data: To communicate with you in respect of the recruitment process.

Our basis for doing so: Collas Crill's legitimate interest.

Collas Crill's legitimate interests (where appropriate): Obtaining your consent where needed for contact. Maintaining proper practice and efficiencies in meeting our legal and commercial obligations. Developing and growing our business.

How Collas Crill uses client data: To enhance any information that we receive from you with information obtained from third party data providers.

Our basis for doing so: Collas Crill's legitimate interest.

Collas Crill's legitimate interests (where appropriate): Maintaining proper practice and efficiencies in meeting our legal and commercial obligations. Developing and growing our business.

How Collas Crill uses client data: To find appropriate candidates to fill our job openings.

Our basis for doing so: Collas Crill's legitimate interest.

Collas Crill's legitimate interests (where appropriate): Maintaining proper practice and efficiencies in meeting our legal and commercial obligations. Developing and growing our business.

How Collas Crill uses client data: To help Pinpoint improve their services.

Our basis for doing so: Collas Crill's legitimate interest. Contract fulfilment.

Collas Crill's legitimate interests (where appropriate): Maintaining proper practice and efficiencies in meeting our legal and commercial obligations.