APPLICANT PRIVACY NOTICE
In this notice, “we”, “us”, “our” and “COMPANY” means HARDING LOEVNER LP, being the entity to which you are applying to work.
About this privacy notice
This privacy notice sets out the categories of your personal information we collect and the purposes for which we use it in accordance with the California Consumer Privacy Act (CCPA).
By personal information we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include consumer information that is deidentified or aggregate consumer information. By consumer, we mean a natural person who is a California resident, however identified, including by any unique identifier.
Please read the information set out below before submitting your CV/resume and/or application form to us.
Personal information that we collect about you
We will collect and process the following personal information about you:
· Information that you provide to us or one of our affiliates. We will process information that you give us by submitting any applications. This information is likely to include:
o your full name, education and qualification details, home address and home telephone number, mobile telephone number, email address, employment history, other application details, your resume / CV, cover letter, copies of your transcripts and/or education certificates, writing sample, results of online tests, assessments and interview information and photograph, if provided;
o information regarding your previous work experience and salary expectations, as applicable;
o immigration information, including a copy of your passport, driver’s license, visa and/or work permit;
o disability information; and
o diversity monitoring information (including race, ethnic origin, gender and sexual orientation).
· Information we obtain from other sources. This is likely to include information about you, such as:
o details of your suitability to work with us, your past performance at work, your character, verification of the information that you provide to us as part of your application, and if legally permitted, any history concerning criminal convictions, from third party references that you provide to us, from your previous and/or current employers, opinions expressed by others about you and from third party background checking services or a previous employer or other referee.
How we use your personal information
Your personal information may be stored and processed by us in the following ways and for the following purposes:
· to assess your job application (including, in some cases, verifying your qualifications, education and references with those third parties you name), for administrative purposes during the recruitment process and to make recruitment decisions;
· to check your right to work in the relevant jurisdiction;
· to allow us to monitor for equal opportunities;
· to make reasonable adjustments in the case of disability;
· for compliance with any legal or regulatory obligation to which we are subject (including compliance with any request from regulatory authorities or other relevant public authorities);
· for the prevention and detection of crime or fraud, subject to local law; and
· in the context of the possible sale or restructuring of all or part of our business or as otherwise permitted or required by law.
In certain circumstances, your failure to provide personal information that we request from you may impact our ability to meet the above purposes.
How to contact us
If you would like further information on the collection or use of your personal information, please submit questions, comments and requests by contacting us at careers@hlmnet.com.
Harding Loevner - Candidate Privacy Notice
As part of any recruitment process, Harding Loevner (UK) Limited (as your prospective employer) and Harding Loevner LP (as the head office involved in recruitment decisions) (“we”, “us”) collect and process personal information relating to candidates. We are committed to respecting your privacy and recognize the need for appropriate protection and management of your personal information shared with us ("Personal Information"). This privacy notice sets out how we process that Personal Information.
Harding Loevner (UK) Limited and Harding Loevner LP are joint data controllers. This means that we are jointly responsible for deciding how we hold and use Personal Information. We have determined that Harding Loevner LP will usually be responsible for our obligations under the UK General Data Protection Regulation.
The kind of information we hold about you
In connection with your application to work with us, we will collect, store, and use the following categories of Personal Information:
- The information you have provided to us in your curriculum vitae and cover letter;
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, employment history and qualifications;
- Any information you provide to us during an interview;
- Application documents generated by Harding Loevner, such as assessment results, feedback and notes from interviews or other selection processes; and
- Reference information.
How is Personal Information collected?
We collect Personal Information from the following sources:
- You, the candidate.
- Recruitment agencies and vendors we have agreed terms in place with.
- Any professional networking or other social media profiles.
- Our employees and others who refer you to us.
- Background check agencies.
- The Financial Conduct Authority or other relevant regulatory or professional body.
How we will use Personal Information?
We will use Personal Information to:
- Assess your skills, qualifications, and suitability for the role and make decisions about the financial package on offer.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- We also need to process your Personal Information to decide whether to enter into a contract of employment with you.
Except where necessary to comply with our legal obligations, each of these ways in which we use Personal Information is in our legitimate interests in maintaining contact with you, making recruitment decisions and maintaining standards of integrity and excellence in our workforce, and ensuring appropriate and attractive financial packages are offered to successful candidates.
Having received your CV, cover letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be screened by our in-house recruitment team for the role. If you do, we will decide whether your application is strong enough to invite you for an interview, be it by telephone, in person or other electronic means. If we decide to engage you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
Special Category Data and Criminal Convictions and Offences Data
In addition, we may process certain ‘special categories’ of Personal Information in some circumstances for the purposes of carrying out our obligations and exercising specific rights in the field of employment law, and/or for the assessment of your working capacity. In limited circumstances we may also be required to process special category data to respond to and defend legal claims. We may process the following particular special categories of Personal Information:
- Medical/health information provided as part of the application process, for example, any details you may give us about a disability. We use this information to make reasonable adjustments to the recruitment process in compliance with our legal obligations and our employment law obligations.
- Immigration information, for example, your passport, driving licence, visa, work permit. We use this information to check your right to work in the UK in compliance with our legal obligations and employment law obligations.
- Medical/health information after any job offer has been made, should you request reasonable adjustments or accomodations.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We may collect information about your criminal convictions history if we have decided to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We may be required or entitled to carry out a criminal records check in order to check that there is nothing in your criminal convictions history which makes you unsuitable for the role. Where applicable, we undertake such checks as part of an application to the Financial Conduct Authority for approval of a senior manager or a non-executive director who is not a senior manager (this is necessary to perform or exercise obligations or rights which are imposed or conferred by law). Otherwise, we undertake such checks to assist with our obligations to the Financial Conduct Authority to assess an individual’s fitness and propriety to perform a Certification Function and/or other such assessments by us which form part of generally accepted principles of good practice (this is in our legitimate interests and is necessary to comply with regulatory requirements).
We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
If you fail to provide Personal Information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully and we will not be able to take your application further.
Automated decision-making
We do not make decisions based solely on automated decision-making.
Data sharing with third parties
- We will only share Personal Information with third-party service providers for the purposes of conducting a background check following our offer, and your acceptance of our offer, of employment.
- All our third-party service providers are required to take appropriate security measures to protect your Personal Information in line with our policies. We do not allow our third-party service providers to use your Personal Information for their own purposes. We only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
Transfers outside of the UK
Personal Information will be processed in the United States as this is where Harding Loevner LP (and some of our other service providers described above) are based, for the purposes described above. This means that Personal Information may be transferred to countries which do not have the same standard of data protection laws as the UK.
Where required, we have put in place standard contractual clauses to require that Personal Information is treated in a manner that is consistent with and respects the UK laws on data protection. If you require further information about this you can request it from the contact details given at the end of this privacy notice.
Data retention (how long is Personal Information kept for)
We will retain Personal Information for a period of one year after we have communicated to you our decision about whether to appoint you to a role so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
- If you agree, we will retain Personal Information for a further one year so that we can make you aware of any suitable alternative roles that arise during this period.
- After this period, or once you withdraw your consent if applicable, we will securely destroy Personal Information in accordance with applicable laws and regulations.
- If your application is successful and you accept our offer of employment, Personal Information gathered during the recruitment process will be transferred to your personnel file and retained during your employment and thereafter for the periods explained in our Employee Privacy Notice which will be provided to you.
If you wish to withdraw your application at any stage, please visit https://recruit.hirebridge.com/v3/CareerCenter/CandidatePortal/login.aspx?cid=7729. Once you have withdrawn your application, we will cease our consideration of your application and, subject to our policies and the retention periods outlined above and whether you have told us that you wish to be contacted about suitable alternative roles in the future, we will securely destroy Personal Information in accordance with applicable laws and regulations.
Rights in relation to Personal Information
Under certain circumstances, by law you have the right to:
- Request access to Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information and to check that we are lawfully processing it.
- Request correction of the Personal Information. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove Personal Information where you have exercised your right to object to processing (see below).
- Object to processing of Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of Personal Information. This enables you to ask us to suspend the processing of Personal Information, for example if you want us to establish its accuracy or the reason for processing it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the processing of Personal Information for a specific purpose, you have the right to withdraw your consent for processing for that purpose at any time.
Compliance Oversight
We have appointed our Chief Compliance Officer (CCO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the CCO by email, at legal&compliance@hardingloevner.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.