This Policy contains important information about how FIL Limited and/or its subsidiaries (together “FIL”) in their capacity as recruiter and future employer, will process as data controllers your personal data in connection with your application for employment. You are asked to read the Policy carefully. In the event that you have any questions on this Policy, please contact us at: firstname.lastname@example.org.
You are hereby informed that you have the right to access your personal data and to request the modification, update, rectification or erasure of personal data. You may exercise these rights by contacting FIL in writing at email@example.com.
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, email address, contact phone numbers, date of birth, employment history, education and qualifications, referees, and memberships of professional bodies etc.
This information will be collected from a number of sources, including your CV, the Background Vetting form, interview notes, cover letter and any other documents generated during the 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. Finally if your application is successful, you will be required to complete a separate Background Vetting form to assess your suitability for employment within FIL.
Sensitive Personal Data
Certain information about an individual is known as sensitive personal data. Subject to and to the extent permitted by local/country legislation and applicable data protection and privacy laws, FIL may process your sensitive personal data during the recruitment process in the context of:
(a) Recruitment and Selection
The primary purpose for processing your personal data is to consider your application for employment as part of FIL’s recruitment process. Your personal data will be used by FIL’s HR Department, managers and other relevant employees who are directly involved in the recruitment process to the extent strictly necessary, during all aspects of the recruitment process, for example to assess your application, during any interview and when finalising any recruitment decision.
(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 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.
(a) Access and Storage
Documents containing your personal data will be accessed and stored by the following individuals: managers and employees of the relevant HR Department for the purposes of the recruitment and selection process - for this purpose, certain details will be stored on Fidelity's electronic recruitment portal Workday which operates on a global basis; and managers and employees who are otherwise directly involved in the recruitment process to the extent strictly necessary to assess your application, during any interview and when finalising any recruitment decision.
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 or other FIL Group companies acting in their capacity as data processors and which may be located in non-EU countries which may not offer a level of data protection equivalent to EU countries.
1 - Transfer within FIL Group companies
Line managers involved in the recruitment process may be located in a jurisdiction (EU or non-EU countries such as India, Singapore, Taiwan, Hong Kong, Bermuda or China which may not offer a level of data protection equivalent to EU countries) which is different than the country where the position is to be fulfilled.
Managers and employees of the HR Department handling the recruitment process within continental Europe may also be located in an EU jurisdiction which is different than the country where the position is to be fulfilled.
2 - Transfer to third parties
FIL's applicant tracking and recruitment portal Workday is a global HR system with data centres in Dublin and Amsterdam. Personal data uploaded on Workday may also be accessed by the mother company Workday Inc. located in the US and its Non-EU affiliates for maintenance and IT support purposes. Workday Inc. has self-certified to the EU-US Privacy Shield.
For purposes of assessment, tests may be carried out in the context of the recruitment process. Email addresses of candidates and test results may also be shared with relevant Talent Assessment service providers in the context of applications to FIL.
(c) Retention of personal data
Successful applicants - If your application for employment is successful, full details of how FIL processes your personal data during the employment relationship will be provided in due course. Any information which you have provided during the recruitment process that is irrelevant to the ongoing employment relationship will be destroyed within a period of no longer than 25 months following the satisfactory completion of the background vetting checks.
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 25 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.