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Privacy Policy

Recruitment Privacy Notice

This website (“Website”) is provided by Brooks Macdonald Group PLC (“Us”, “We”, “Brooks Macdonald”) which is the holding company of:

  • Brooks Macdonald Asset Management Limited;
  • Brooks Macdonald Financial Consulting Limited;
  • Brooks Macdonald Funds Limited;
  • Brooks Macdonald Asset Management (International) Limited; and
  • Brooks Macdonald Retirement Services (International) Limited

Brooks Macdonald is committed to protecting the privacy of the people that we receive information about. This means that we take steps to lawfully and fairly process any personal data that is made available to us, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) and any other applicable domestic legislation (the “Data Protection Laws”).

This Privacy Notice (“Notice”), together with our Cookie Policy [www.brooksmacdonald.com/site-services/privacy-and-cookies] sets out the basis on which we will process your personal data. If you have any queries about this Notice or how we use your data, you can contact us using the contact details below.

When we refer to “personal information” or “personal data" in this Notice, we mean information which identifies you as an individual, or is capable of doing so. In the context of this Notice, the terms “personal information” and “personal data” may be used interchangeably.

Please read this Notice carefully. By providing your personal data to us and/or applying to use our services, you acknowledge that your personal data will be used in accordance with this Notice and our Cookie Policy.

When Do We Collect Information?

This Notice explains how we will protect your information gathered via this Website and during the online application and registration process. The online application and registration process will be completed on the applicant tracking system provided by our software provider (Networx). A link to the online application and registration process will be on the Website. If you choose to submit personal information to this Website, you agree to the use of such data in accordance with this Notice. You do not have to submit any personal information in order to use the Website, however, the Website will collect any and all personal information that is voluntarily provided by you.

We will be the data controller, as defined under applicable Data Protection Laws, of any personal data which we collect from or about you.

What Information Will We Collect?

As part of the application process, we will collect personal information that is specifically provided by you, including the following (but not limited to):

  • Contact details including you name, address, email and telephone number
  • CV (if applicable)
  • Equal opportunities monitoring information (defined as special category data)
  • Answers to application questions
  • Any other information you wish to provide in support of your application

Why will we collect your information and how will we use it?  

We will typically use and collect this personal information for the following purposes (other purposes that may also apply are explained in our Employee Privacy Notice):

  • For compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom). 
  • For the purposes of our legitimate interests to assess your suitability for the position, but only if these are not overridden by your interests, rights or freedoms.

We may use, collect and share your information (including but not limited to, information from cookies, log files, location data and usage data) with businesses that are legally part of the same group of companies within Brooks Macdonald, or that become part of that group , in order to facilitate the objectives listed in this Notice. Information will be shared with third parties where this is necessary to enable us to comply with our legal or regulatory obligations.

Personal data which you provide in this application/registration, or separately in connection with your application/registration will be held on our computer systems and/or on a manual file, and may/will be used for legitimate human resources and business management purposes, including:  

  • Your application;
  • Communication with you regarding recruitment;
  • To satisfy legal requirements and for statistical analysis;
  • To contact you about future vacancies;
  • To be processed, transferred and stored by our software provider (Networx). 

How We Protect Your Information

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.

Disclosure of Your Information

We may disclose your information:

  • To businesses that are legally part of the same group of companies within Brooks Macdonald, or that become part of that group;
  • To our IT providers, third party service providers and agents in order to provide and maintain the provision of the services;
  • To our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information in order to advise us;
  • If required to do so by the Financial Conduct Authority, Jersey Financial Services Commission, Guernsey Financial Services Commission or any relevant regulatory authority where they are entitled to require disclosure;
  • If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
  • To investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
  • If any one of the Brooks Macdonald Group companies or substantially all of its assets are acquired by a third party, in which case personal data held by it about its employees or prospective employees may be one of the transferred assets.

We will not lend or sell your information to third parties.

Data Retention

We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Notice, and for as long as we are required or permitted to keep it by law.

If you accept an offer of employment, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with jurisdictional data retention requirements. If we do not employ you, we may nevertheless continue to retain and use your personal data for a period of 6 months after the recruitment exercise has been completed  for system administration purposes, to consider you for potential future roles, and to perform research.

Special Category Data

Data Protection Laws define the following as special category data:

  • Data revealing your racial or ethnic origins, your political opinions, religious or philosophical beliefs, or any trade union membership you may hold;
  • Data concerning your health, your sex life or your sexual orientation.

These are types of data that the law recognises merit higher protection than other categories of personal information.

As part of our recruitment process, we may process special category data, such as information about ethnic origin, sexual orientation, health or religion or belief, for equal opportunities monitoring purposes.

Where the information you provide involves special category data, our lawful basis for processing the special category data will be for the purposes of our legitimate interests or those of a third party (such as a benefits provider) to enable us to carry out equal opportunities monitoring but only if these are not overridden by your interests, rights or freedoms, and/or for compliance with a legal obligation e.g our obligation to check that you are eligible to work in the United Kingdom. In addition to this and as a separate condition for processing your special category data pursuant to the Data Protection Laws, we will collect and use your special category data to carry out our obligations or exercise our rights in connection with employment law.

Transferring Information Overseas

We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with Data Protection Laws and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.

We may transfer your personal information between businesses that are legally part of the Brooks Macdonald group of companies for the purposes of providing our services to you as follows:

  • From our businesses based in the United Kingdom to our businesses based in Jersey or Guernsey on the basis that the European Commission has given a formal decision that such countries provide an adequate level of data protection similar to that which applies in the United Kingdom and EEA; and
  • From our businesses based in Jersey or Guernsey to our businesses based in the United Kingdom on the basis that the United Kingdom is an authorised jurisdiction for the purposes of the relevant Data Protection Laws.

Your Rights  

You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details below. The right:

  • To ask us not to process your personal data for marketing purposes;
  • To access personal information held about you and to obtain a copy of it;
  • To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
  • To request the rectification or completion of personal data which are inaccurate or incomplete;
  • To restrict or object to the processing of your personal data and to request its erasure under certain circumstances;
  • In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
  • To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
  • To lodge a complaint about the way in which your personal data is being used to your Data Protection Authority: the Information Commissioner's Office (United Kingdom), the Office of the Information Commissioner (Jersey) and the Office of the Data Protection Commissioner (Guernsey).

When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.

If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us via our contact details below.

Alternatively, if you would like to contact your Data Protection Authority, please use the contact details below.

United Kingdom:  Information Commissioner’s Office [https://ico.org.uk/global/contact-us/]

Jersey:  The Office of the Information Commissioner [https://dataci.je/contact-us]

Guernsey: The Office of the Data Protection Commissioner [https://dataci.gg/contact-us]

Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.

Cookies 

Our Website uses cookies to distinguish you from other users to enable us to provide you with a better experience when you browse our Website and to allow us to improve our site. For more information, please visit our Cookie Policy [www.brooksmacdonald.com/site-services/privacy-and-cookies].

Changes To Our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on this webpage. This Privacy Notice was last updated in May 2018.   

How To Contact Us

If you or any third party whose personal information you have supplied to us have any queries, comments or requests regarding this Notice or would like to exercise any of the rights set out above, we can be contacted at:

E-mail: DPO@brooksmacdonald.com

Post:

United Kingdom: Data Protection Officer, Brooks Macdonald Group plc, 72 Welbeck Street, London W1G OAY

Guernsey: Data Protection Officer, First Floor, Royal Chambers, St Julian`s Avenue, St Peter Port, Guernsey, GY1 2HH

Jersey: Data Protection Officer, First Floor Liberation House Castle Street St Helier Jersey JE4 9ZW