This notice applies to you if:
- You contact us in relation to becoming an employee, worker or contractor of ours.
- Your personal information is provided to us by a third party in relation to you becoming an employee, worker or contractor of ours (e.g. by a recruitment agency or one of our employees).
- We obtain your personal information to consider your suitability to become an employee, worker or contractor of ours.
If you become an employee, worker or contractor of ours, we will continue to use your personal information as set out in our Privacy Notice for Employees, Workers and Contractors, which we will provide to you. If you do not become an employee, worker or contractor of ours, we will continue to use your personal information as set out in this notice.
In this notice, “we” “us” and “our” refers to Winton Capital Management Limited and any other Winton group entity or entities that are involved in the selection or recruitment processes related to you. This may include Winton Capital US LLC, Winton Capital Asia Limited, Winton Capital Switzerland AG, Winton Capital Australia PTY Limited, Winton Capital Japan Co. Limited and Winton Investment Management (Shanghai) Limited.
We are a “data controller”. This means that we are responsible for deciding how we use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
Your personal information
We may collect, store and use the following categories of personal information about you:
- Personal details such as name, title, addresses, telephone numbers, email addresses, date of birth, gender, nationality.
- Recruitment information such as CV, employment history, education history, current and prior compensation, references, interview notes and results of background screening checks..
Collection of your personal information
We collect your personal information through our selection and recruitment processes. Information may be collected directly from you, or from third parties such as employment agencies, background check providers, former employers, educational institutions, public agencies and credit reference agencies.
Lawful basis for processing
We can only use your personal information when the law allows us to (i.e. there is a “lawful basis for processing”). Most commonly, the lawful basis will be one or more of the following:
- Where it is necessary for our legitimate interests (or those of another Winton group entity) and your interests and fundamental rights do not override those interests. Depending on the type of personal information, these legitimate interests are: selecting and recruiting appropriate individuals to work for us; making a decision about whether to appoint you and on what terms; assessing the effectiveness of and making improvements to our selection and recruitment processes; and complying with non-EU or non-EU member state law.
- Where we need to comply with EU or EU member state law.
Purpose for processing
We may use your personal information for the following purposes:
- Assessing your skills, qualifications and suitability for the relevant role(s) and making a decision about who to appoint for the role(s).
- Communicating with you about our selection and recruitment processes.
- Determining the terms on which you work for us.
- Keeping records related to our selection and recruitment processes.
- Checking you are legally entitled to work in the relevant country.
- Ascertaining your fitness to work.
- Dealing with legal disputes involving you or others.
- Complying with health and safety obligations.
- Preventing fraud.
- Complying with legal or regulatory requirements.
If you fail to provide personal information
If you fail to provide certain information when requested, you may be excluded from our selection and recruitment processes or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for such use.
Sharing personal information
We will share your personal information with third party service providers and other Winton group entities for one or more of the legal bases set out above. Third party service providers and other Winton group entities are required to take appropriate security measures to protect your personal information.
We may need to share your personal information with providers of services related to:
- Recruitment and human resource administration (e.g. Jobvite, Workday, Vero, Risq Group and Aurico).
- Background screening (e.g. Vero, Risq Group, Aurico).
- IT and information security (e.g. Microsoft, Mimecast, Cofence, Tessian, Mir3, iManage and Palo Alto Networks).
- Legal, finance and tax matters (e.g. Withers, Workday, Proactis, Ernst & Young, Deloitte, KPMG and PwC).
We may also need to share your personal information with:
- Regulators or other third parties (e.g. tax authorities) to comply with the law.
- Third parties in the context of the possible sale, listing or restructuring of the business.
Service providers and Winton group entities that receive your personal information may be based anywhere in the world, including countries outside the EU such as Australia, Hong Kong, India, Japan, The People’s Republic of China, Switzerland and the United States of America. Such countries may not be subject to a decision by the European Commission that their laws provide an adequate level of protection for personal information. Therefore, to ensure that your personal information receives an adequate level of protection, we ensure that, where required by law, transfers of personal information outside the EU are subject to European Commission-approved standard data protection provisions or, in respect of transfer to the US, the transferee is a participant of the EU-US Privacy Shield framework.
Retention of your personal information
If you are successful in obtaining a role with us, we will retain your CV and other personal information we obtain as part of our selection and recruitment processes in accordance with our Privacy Notice for Employees, Workers and Contractors. If you are not successful in obtaining a role with us, we will retain your information for up to two years from the date on which such information is uploaded to our recruitment system, or longer if we notify you of this and you do not object.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Our retention period for information of unsuccessful candidates allows us to consider you for other roles that we believe may be suitable for you (or the original role if this becomes available again).
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the selection or recruitment process.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your 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 your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest 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 your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want exercise any of these rights, please email firstname.lastname@example.org.
You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Changes to this privacy notice
We may update this privacy notice at any time and we will post the updates on www.winton.com. Please check back regularly so that you are aware of any updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact and complaints
If you have any questions about this privacy notice or how we use your personal information, please email email@example.com.
You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues.