Recruitment Data Protection Privacy Notice

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during our recruitment application process. We are required to notify you of this information, under data protection legislation.

Please note that this privacy notice only relates to information we collect from you as part of our recruitment process. For more information on other types of information we may collect from you through our website, please see our website privacy notice: https://www.form3.tech/policy.

Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’ or ‘privacy policy’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

FORM3 GROUP LIMITED (company registration number: 13762564, registered office address at 16 Great Queen Street, London, United Kingdom, WC2B 5AH) (‘Form3 / “we”“our” “us”) is a ‘data controller’ and gathers and uses certain information about you in order to process your job application. In this notice, references to ‘we’ or ‘us’ mean Form3.

If any personal data from the recruitment process will be shared across the Form3 entities or if any recruitment processes sit within other Form3 entities then we will need to amend this so that the “controller” includes the Form3 Group and the other Form3 entities.

We will comply with the following data protection principles when processing personal information:

• we will process personal information lawfully, fairly and in a transparent manner
• we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
• we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
• we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information are deleted or corrected without delay;
• we will keep personal information for no longer than is necessary for the purposes for which the information is processed; and
• we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

We may collect the following information up to and including the shortlisting and interview stage of the recruitment process:

We can only process personal information about you where we have a lawful basis for doing so, and in addition, if the data is special category data, we are also required to identify a special category processing condition.

We collect the above information from you directly. We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Special categories of data or data that may be considered sensitive (such as information about ethnic origin, sexual orientation, health or religion or belief, age, gender or marital status) and information regarding any disability you may have is only collected with the explicit consent of candidates, which can be withdrawn at any time. Candidates are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Where you are successful in your application for a job with us, we will collect additional information about you from you, your referees (whose details you provide), education providers or professional bodies (as applicable). This may include information such as criminal history, certain health data and/or supporting documentation about your application. The processing of such additional information is covered by our Employee Privacy Notice, which will be presented to you at the time we collect such information.

Your information will only be seen and used by our employees who have a legitimate business need to access your information for recruitment purposes. We may also share your information or data with trusted third parties who help us manage our recruitment strategy. In particular, we engage the following third party suppliers:

• Greenhouse Software Inc, who provides a cloud-based recruitment platform which helps us manage applications and monitor the process of our recruitment cycles; and

• Metaview Global Limited, who provides an interview analytics platform which helps us to improve the quality of our interviews. We will only share your personal data with Metaview if you have consented to such sharing.

We may also need to share some of the above categories of personal information with other parties, such as our professional advisers (e.g. lawyers or HR advisors). Usually, information will be anonymised but this may not always be possible.

Any recipients of the information will be bound by confidentiality obligations. They have access to the information needed to perform their functions, but may not use it for other purposes.

We also have to share information or data in order to:

• meet any applicable law, regulation, legal process or enforceable governmental request;

• enforce applicable policies, including investigation of potential violations;

• detect, prevent, or otherwise address fraud, security or technical issues; and

• protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.

Information may be held at our offices and third party agencies, service providers, representatives and agents as described above.

We keep the information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment as set out in our Employee Privacy Notice, which will be made available to you after your application is successful.

If you have opted out or otherwise told us directly that you do not want to receive direct marketing communication or have asked us to remove your personal data from our database or marketing list, we may keep your contact details on our “suppression list” (which is a list of those who have opted out of or otherwise objected to receiving marketing communications from us), to ensure that we will not use your details for any further direct marketing purposes and for us to comply with our legal obligations.

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact us using the information below (at the bottom of this privacy notice) if you wish to object in this way.

Please contact us using the information below if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

We hope that we can resolve any query or concern you raise about our use of your information by contacting us using the details below. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

Point of contact: Head of Talent

Email: careers@form3.tech