Privacy Policy
Saffery Trust (Guernsey) Limited (“we”, “us”) is committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Saffery Trust (Guernsey) Limited.
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions
Where you apply for an opportunity posted by us, these Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice which is available on our website.
Your Personal Information
Information we collect from you
We collect and process some or all of the following types of information from you:
- Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method;
- In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience and any information relating to your employment history, skills and experience that you provide to us;
- Information about an individual’s current level of remuneration, including benefits received;
- Information on whether or not an individual has a disability for which the firm needs to make reasonable adjustments during the recruitment process;
- Information about an individual’s entitlement to work in Guernsey; and
- Equal opportunities monitoring information, including information about gender, ethnicity, age, marital status and nationality;
- If you contact us, we may keep a record of that correspondence;
- Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.
Information we collect from other sources
Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.
We collect this information in a variety of ways. Data might be contained in applications, CVs or resumes, or gathered through interviews or other forms of assessment processes. This information is collected in hard copy or electronically.
We also collect personal data about individuals from third parties, such as references supplied by former employers, and information from criminal records checks. We will seek information from third parties only once a job offer has been made and with the express permission of the individual.
Uses made of your information
Lawful basis for processing
Uses made of your information
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which we collect and use your personal data.
In some cases, we need to process data to ensure that the firm is complying with its legal obligations. For example, we are required to check a successful applicant's eligibility to work in Guernsey before commencing employment.
Saffery has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the firm to manage the recruitment process, assess and establish a candidate's suitability for employment and decide who to offer a job to.
Purposes of processing
Purposes of processing
We use information held about you in the following ways:
- To consider your application in respect of a role for which you have applied;
- To consider your application in respect of other roles;
- To communicate with you in respect of the recruitment process;
- To enhance any information that we receive from you with information obtained from third party data providers;
- To find appropriate candidates to fill our job openings;
- To help Pinpoint improve their services.
Automated decision making / profiling
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.
How we store your personal data
Security
How we store your personal data
Security
We take the security and protection of personal data seriously. We have internal policies and controls in place to ensure that personal data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our trained staff and managers in the proper performance of their duties. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Data is stored in a range of different places, including on an initial application record, in our People & Culture (P&C) database and on other IT systems including email.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
Who has access to data?
Personal data will be shared internally for the purposes of the recruitment exercise. This includes members of the P&C department, directors, partners, managers and other staff appropriately trained and involved in the recruitment process.
Where we store your personal data
The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.
How long we keep your personal data
If an individual’s application for employment is unsuccessful, we will hold personal data on file for six months after the end of the relevant recruitment process. At the end of that period, or once an individual withdraws their consent, personal data is securely deleted or destroyed.
If an individual provides permission for us to hold their data on file for the purpose of contacting them with future potential opportunities, this will be securely deleted or destroyed unless they provide permission for this to be kept for a further six months for the same purpose.
If an individual’s application for employment is successful, personal data gathered during the recruitment process will be transferred to the individual’s personnel file and retained during employment. The periods for which personal data is held will be provided to an individual in our data retention policy.
Your personal information can be deleted by one of the following:
- Deletion of your personal information by you via the Manage Your Data tool or
- Receipt of a written request by you to us.
Your rights
Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:
- Access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
- Require us to correct any mistakes in your information which we hold
- Request the erasure of personal data concerning you in certain situations
- Request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal data concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal data
- Otherwise restrict our processing of your personal data in certain circumstances
- Ask us to stop processing personal data for a period if data is inaccurate or there is a dispute about whether or not an individual’s interests override the firm's legitimate grounds for processing personal data.
If you would like to exercise any of those rights, please either:
- Utilise the Manage Your Data tool provided or;
- Contact us at dpo@saffery.gg, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates.
We hope that we can resolve any query or concern you raise about our use of your information. However, if you believe that we have not complied with your data protection rights, you can complain to The Office of the Data Protection Commissioner https://odpc.gg/.
What if an individual does not provide personal data?
What if an individual does not provide personal data?
An individual is under no statutory or contractual obligation to provide data to us during the recruitment process. However, if they do not provide the information, we may not be able to process their application for recruitment purposes.
An individual is under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for an individual’s application if they choose not to provide such information.
Changes to this Privacy Notice
Changes to this Privacy Notice
This Notice does not form part of any employment contract.
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.