This Policy contains important information about how FIL Investment Management Ltd (known together with its associated companies as Fidelity) and its associated companies (together “FIL”) will process your personal data in connection with your application for employment. You are asked to read the Policy carefully before completing the Background Vetting Form. In the event that you have any questions on this Policy, please contact us at


FIL will collect your personal data as may be necessary to process your application for employment as part of its recruitment and selection procedure. This personal data will include (but is not limited to): your name, address and previous addresses, date of birth, employment history, education and qualifications, referees, hobbies, outside interests and memberships of professional bodies etc.

This information may be collected from a number of sources, including your CV, the Background Vetting Form, interview notes, correspondence and any other documents generated during the recruitment process. 

The primary purpose for processing your personal data is to consider your application for employment as part of FIL’s recruitment process. In the event that your application for employment is successful, this data may also be retained and processed for the purpose of the ongoing employment relationship (further information on this processing will be provided to you as needed). Finally, as explained below, the information which you provide may also be used to assess your suitability for employment as part of FIL’s background vetting procedure.

Sensitive Personal Data

Certain information about an individual is known as sensitive personal data. FIL may process your sensitive personal data during the recruitment process as follows:-

  • Criminal convictions and pending proceedings – subject to Regional/Country legislation and local data protection and privacy laws.
  • Medical conditions and disabilities – subject to Regional/Country legislation and local data protection and privacy laws.
  • Equal Opportunities Monitoring – subject to Regional/Country legislation and local data protection and privacy laws.


(a) Recruitment and Selection

Your personal data will be used by FIL’s HR Department, managers and other relevant employees during all aspects of the recruitment process, for example to assess your application, during any interview, finalising any recruitment decision, to send your contract pack if your application is successful and to ask you to provide feedback on your experience throughout the recruitment process.

(b) Background Vetting

FIL considers it owes a duty to its customers, clients and business to ensure that it maintains the highest standards of honesty and integrity when recruiting for its workforce. As a result, it is FIL’s policy to undertake background checks on all applicants who are offered employment following the recruitment process.

The checks described below will only be undertaken once a successful applicant has signed and returned an offer of employment. 

The checks are as follows:-

  • Applicant’s identity and rights work;
  • Consistency in information provided on CV’s, Interview Notes & BVF;
  • Publicly Held Database checks - including international Database checks but not limited to;
  • Credit/Directorship information;
  • Verification of employment – over the previous 5 years (or min of 2 employers);
  • Verification of highest level of education(attained at degree level or above, or any education attained within the last 5 years);
  • Verification of professional certifications or affiliations that are relevant to the role to be undertaken;
  • Verification of any relevant regulatory authorisations;
  • Criminal Checks – role specific and/or where legislation allows.

The background vetting process may differ according to the country of employment and employment category, it is also necessary to adhere to strict Data Protection requirements.  

It is essential that you complete the Background Vetting Form in full and that any information which you provide on the Form (and otherwise during the recruitment process) is honest, accurate and not misleading. In the event that a discrepancy is discovered during the conduct of the background checks, an applicant will usually be given the opportunity to provide an explanation. However, all applicants should note that, should such explanation be unsatisfactory, or if FIL otherwise determines (in its absolute discretion) that the results of the background checks are a cause for concern, this could lead to any offer of employment being withdrawn or, where employment has commenced, the immediate termination of the employment relationship (including summary dismissal in appropriate cases). In line with the above, all offers of employment made by FIL are expressly conditional upon a satisfactory background check being completed in relation to each applicant.


(a) Access and Storage

Documents containing your personal data will be accessed and stored by the following individuals:-

Managers and employees of the HR Department for the purposes of the recruitment and selection process - for this purpose, certain details will be stored on Fidelity's electronic Recruitment Database which operates on a global basis; managers and employees of the Investigations & Intelligence Department for the purposes of conducting background vetting checks (in relation to applicants who have accepted an offer of employment); and managers and employees who are otherwise directly involved in the recruitment process (e.g. line managers involved in the interviewing process).

In all cases, Fidelity takes appropriate steps to ensure that the documents are stored securely (whether in hardcopy or softcopy) and that access is restricted only to those employees with a legitimate purpose.

(b) Transfer to third parties (including other FIL Group companies)

In a very limited number of cases, an applicant’s personal data may be transferred to other third parties for the conduct of the background vetting checks. Such transfer will only take place (i) where an applicant has accepted an offer of a contract to provide services; and (ii) he/she has worked or resided abroad for a significant period within the last five years. In this event, personal data may be transferred as follows for assistance with the conduct of the background vetting checks (third party/relevant location(s)): HireRight; UK and Poland (Europe), FMR Corporation, Merrimack; (US, Canada), First Advantage (FADV);  Tokyo (Japan), China, Hong Kong (Far East and Australia), Taipei (Taiwan) Delhi (India) and Verifacts Services Pvt Ltd; Gurgaon. In each case, the transfer takes places under the terms of an agreement which deals with the protection of your personal data.

(c) Retention of personal data

Successful applicants - If your application for employment is successful, any information which you have provided during the recruitment process will be retained only if it is relevant to the ongoing employment relationship. Full details of how FIL processes personal data during the employment relationship will be provided in due course as needed. Any other information which you have provided during the recruitment process will be destroyed within a period of no longer than 6 months following the satisfactory completion of the background vetting checks. This includes all documents generated during the conduct of background checks including the Background Vetting Form, although a summary note of the results of the checks and any significant points will be retained (along with any related documents).

Unsuccessful applicants - In the event that your application for employment is unsuccessful on this occasion, any information which you have provided during the recruitment process will be retained for a maximum period of no longer than 6 months in order to deal with any queries or issues relating to your application, following which it will be destroyed. The HR Department may write to an unsuccessful applicant to state that his/her CV will be retained on file for the purposes of future recruitment – individuals will be given the opportunity to object to their CVs being retained for this purpose at the relevant time.