Privacy Notice Job Applicants

PRIVACY NOTICE – JOB APPLICANTS

1. INTRODUCTION
This notice sets out the basis on which Liberum Wealth Limited (“we”, “us” or “our”) processes any “personal
data” (that is, any information about an identified or identifiable living person) that you may provide to us
through the Liberum Careers Portal, and any other personal data that we may receive from you or any third parties (such as referees) in connection with a job application.

If anyone else (such as a recruitment agent) represents you in dealings with us, or if you provide personal data
about other individuals (such as referees) in connection with your application, this notice also applies to the
processing of their personal data.

In processing personal data in connection with your application, we are a “controller” of personal data for the
purposes of the Data Protection (Bailiwick of Guernsey) Law, 2018 and related legislation (the “Data
Protection Law”). The Data Protection Law is based on the EU’s General Data Protection Regulation
(“GDPR”), and has been formally recognised by the EU as providing an adequate level of data protection. Like
the GDPR, the Data Protection Law protects personal data by granting various rights to individuals in relation
to the processing of their personal data and imposing certain obligations on controllers and processors of
personal data, among other measures.

2. THE DATA CONTROLLER
Liberum Wealth is a controller of any personal data that we receive in connection with your job application.
You can contact us by email at [email protected], by telephone at +44(0)1481750786, or by
post at:

Liberum Wealth Limited
ATT: Compliance
1st Floor
Royal Chambers
St Julian’s Avenue
St Peter Port
Guernsey
GY1 3JX

3. WHAT PERSONAL DATA DO WE COLLECT?
The personal data that we collect and process in connection with your application will generally include your:
name, date of birth, contact details, work experience, educational qualifications, nationality and other
information relevant to your right to live and work in Guernsey, any further personal data that you choose to
submit or upload in connection with your application (for example, additional personal data included in your
CV), and information relating to any criminal or regulatory record that you may have.

In addition, if you register on the Liberum Careers Portal, we may collect certain data (such as your IP address)
relating to your usage of the portal.

We may also collect personal, contact and other details relating to third parties such as referees and
recruitment agencies, to the extent relevant to your application.

4. SPECIAL CATEGORY DATA
Certain types of personal data are recognised as being particularly sensitive, and are accordingly given a
higher level of protection under the Data Protection Law. These are referred to in the Data Protection Law as
“special category data”, and include, for example, personal data about a person’s race or ethnicity, health, or
criminal record.

The personal data that we collect in connection with your application might include special category data: for
example, we may collect criminal data in the course of carrying out background checks to determine whether
you are suitable for (and meet any regulatory requirements applicable to) the role for which you are applying.

5. PURPOSES OF AND LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA
The Data Protection Law sets out the grounds on which personal data may lawfully be processed. We will only
process your personal data to the extent that one of these grounds (or “legal bases”) applies.

The table in Appendix 1 sets out how, why and on which legal bases we might process personal data in
connection with your application.

6. WHO DO WE COLLECT PERSONAL DATA FROM?
For the most part, we will collect personal data relating to your application directly from you, as the job
applicant.

However, we may also collect personal data relating to your application from third parties such as your chosen
referees, recruiters (if applicable) and businesses that provide screening and background check services.

7. WHO MIGHT WE SHARE YOUR PERSONAL DATA WITH?
We may need to share personal data with third parties in order to assess and process your application. Such
third parties might include companies affiliated with us, screening and background check service providers,
and your chosen referees.

We do not expect that we will need to share your personal data with any person (other than you or your chosen
referees, if applicable), or otherwise transfer your personal data, outside of Guernsey, the UK and the
European Economic Area (“EEA”). However, in the event that we do need to transfer your personal data
outside of these jurisdictions, such transfer will be subject to the applicable protections set out in the Data
Protection Law.

8. RETENTION AND SECURITY OF PERSONAL DATA
If your application is unsuccessful, we may retain the information collected in connection with the application
for up to one year, except to the extent that it may be necessary for us to retain the information for a longer
period to comply with any applicable legal or regulatory requirements, or unless specifically agreed otherwise
with you.

If your application is successful, we will retain information collected in connection with your application for the
duration of your employment with us and for a period of six years following its termination.

Our data retention policies are based on legal prescription periods and statutory and regulatory record keeping
requirements.

We take appropriate measures to keep all personal data that we hold or control secure.

9. YOUR RIGHTS
In summary, the Data Protection Law gives you the following rights in relation to the personal data about you
that we process:

• Information: You have the right to certain information about the processing of the personal data:
  the purpose of this privacy notice is to give you the requisite information.
• Portability: where we process any of the personal data by automated means, you have the right
  to require us to give that personal data to you, or transmit it to another person, in a structured,
  commonly used and machine-readable format.
• Access: You have the right, on request, to copies of the personal data (subject to a reasonable
  administrative charge, if you request more than one copy)
• Objection to processing for certain purposes: You have the right to object to the processing
  of the personal data for certain purposes, including direct marketing. Any marketing that we send
  to you will also give you the opportunity to opt out of receiving any further marketing from us.
• Rectification: You have the right to require us to rectify any of the personal data that is inaccurate
  or incomplete.
• Erasure: You have the right to require us to erase the personal data in certain circumstances (for
  example, if we no longer need the personal data for the purposes for which they were collected).
• Restriction of processing: You have the right to restrict us from processing the personal data
  (which will generally entail that we will continue to store the personal data but will not be able to
  use it for any other purpose without your consent), in certain circumstance (for example, pending
  the resolution of a dispute about the accuracy or completeness of the personal data).
• Decisions based on automated processing: you have the right not to be subject to decisions
  based on the automated processing of the personal data, without your consent. Your application
  will not be subject to automated decision-making processes.
• Withdrawal of consent: if we are relying on your consent to process the personal data for a
  particular purpose, you have the right to withdraw that consent at any time. Note that a withdrawal
  of consent will not affect the lawfulness of any processing of the personal data on other permitted
  grounds (for example, where the processing is necessary for the performance of a contract with
  you, or to comply with our legal or regulatory obligations).

10. CHANGES TO THIS PRIVACY NOTICE
We may update or amend this privacy notice from time to time, and any such updates or amendments will
be reflected under the ‘careers’ tab of our website, www.liberumwealth.com. Please check this page
regularly while we are considering your application and during the retention period referred to in paragraph
8, to ensure that you understand how and why we process personal data collected in connection with your
application.

We may also contact you in other ways regarding the processing of your personal data.

11. QUESTIONS, COMPLAINTS AND EXERCISE OF RIGHTS
Please contact us using the details provided in paragraph 2 above if you have any questions, or if you wish to
make a complaint or exercise any of your rights, in connection with our processing of your personal data.
Please note that we may need to verify your identity before we are able to respond to any such communication.

We are committed to meeting our obligations as a data controller under the Data Protection Law. However, if
you have brought any issue concerning data protection to our attention, and we have not resolved the issue
to your satisfaction, you are entitled to refer a complaint to Guernsey’s Data Protection Authority:
https://www.odpa.gg/for-individuals/make-a-complaint/ .

APPENDIX I – PURPOSES AND LEGAL BASES FOR PROCESSING CANDIDATES’ PERSONAL DATA