Job Applicant Data Protection Notice

Fair Market Value Capital Partners (UK) Ltd

February 2020

The aim of this Data Protection Notice (“Job Applicant Notice”) is to inform individuals who apply for a job or work experience at Fair Market Value Capital Partners (UK) is a limited company incorporated in England and Wales with registered number 06240840. Fair Market Value Capital Partners (UK)’s registered address is 62 Leinster Square, London, W2 4PS (“FMVCP”), on the collection, use, disclosure, transfer, and other processing of their individually identifiable information (“Personal Data”). Under applicable European laws, including but not limited to, laws implementing the General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act (the “Data Privacy Laws”), FMVCP is the data controller.

Personal Data

Throughout the course of your application process with FMVCP, we collect and process certain Personal Data about you. We collect and process your Personal Data (a) for purposes that are required by applicable law and regulations, (b) to allow FMVCP to fulfil its business needs and legal obligations, and (c) to process your job application. The Personal Data we collect and process includes the following categories (where applicable to the application): 
- Contact information: such as full name, including title, name at birth and preferred name, home address, home phone number, personal email address, mobile phone number and any current work contact details provided to us. 
- Master data and qualified HR data: such as proposed job function and contractual details, education information, CV, nationality, passport information, residency status, date of birth, birth city and country, gender, marital status, primary language, language skills, visa type and work permit. 
- Job applicant information: such as candidate details, status, current employer, job history, work and corporate title, education, qualifications, references, criminal record checks, desired function and work location, licenses, certificates, work experience, CV, public searches, including of social media. 
- Compliance information: information required for regulatory or compliance purposes, such as information relating to political donations, outside business activities and information relating to personal account dealing.

Sources of Personal Data

We may obtain Personal Data from the sources listed below: 
- directly from you, the application process or via other forms or information you provide to us in connection with your job application; 
- from third parties, including recruiters and employment agencies, references from third parties and other background screening checks, subject to the requirements of applicable law, and from former employers. 

Information about dependants/contacts

FMVCP collects, processes, and otherwise uses your Personal Data for purposes (a) that are required by applicable law and regulations (b) to allow FMVCP to fulfil its business needs and legal obligations and (c) to process your job application. These purposes also include: 
- the exercise of our rights under local laws and compliance with applicable legal and regulatory requests and obligations (including investigations in relation to the same) and audit requirements; and to establish or defend legal claims and allegations. 

We will not use your Personal Data for the purposes of marketing to you unless you expressly consent to us doing so. 

Disclosure of Personal Data

We will share your CV, bios and any other application details within the Group during the recruitment process for our legitimate business interests. Except in this regard, your Personal Data will be disclosed within FMVCP only to those individuals who need access to your Personal Data to perform their duties or where required or permitted by applicable law. 
FMVCP may also disclose your Personal Data to third parties, including those providing information technology support or technical and organisational services in connection with human resources-related activities or legal, compliance audit or other advisors to FMVCP for the purposes referred to in this Notice. FMVCP will exercise appropriate due diligence in the selection of its third party service providers, and require that such providers maintain adequate technical and organisational security measures to safeguard your Personal Data, and to process your Personal Data only as instructed by FMVCP and for no other purposes. 

Legal basis for processing Personal Data

FMVCP’s employment obligations and contractual obligations, the need to take pre-contractual steps and its legal obligations as well as its legitimate business interests under the Data Privacy Laws form the legal basis of the processing described in this Notice. Our legitimate interests or those of a third party include our requirements to use your Personal Data in litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving FMVCP and may also include the need to transfer your Personal Data to third countries without adequate data protection laws. In this event, we will take reasonable steps to protect your Personal Data as required by the Data Privacy Laws.

Data security

We maintain physical, technical, and organisational security measures to protect the Personal Data against accidental, unlawful, or unauthorised destruction, loss, alteration, disclosure, or access, whether it is processed in your local jurisdiction, the United States, or elsewhere. Our Information Security policy governs how we protect your Personal Data.

Retention, Access and Accuracy of Personal Data

We intend to keep your Personal Data accurate and up-to-date. We also strive to retain your Personal Data no longer than is necessary to carry out the purposes listed in this Job Applicant Notice or than is required by law. FMVCP retains your Personal Data for a maximum of seven years following the end of your job application process or, if you become employed or engaged, from the end of your employment or other business relationship.
Under applicable law, you have rights to: (i) check whether we hold Personal Data about you and to access such data (subject to applicable laws); (ii) request correction of Personal Data about you that is inaccurate; (iii) ascertain information related to FMVCP’s policies and practices in relation to Personal Data; (iv) request the erasure of your Personal Data; and (v) request the restriction of processing concerning you. In certain circumstances, you also may have the right to request restrictions or object for legitimate reasons to the processing of your Personal Data in accordance with the Data Privacy Laws. Further, you have the right to transfer your Personal Data to third parties pursuant to Article 20 of the GDPR.

Rights to raise concerns

You have the right to raise concerns to FMVCP or to a supervisory authority about FMVCP’s processing of your Personal Data. If you wish to raise concerns with FMVCP, please contact The applicable supervisory authority of FMVCP is the Information Commissioner’s Office in the UK.