At Hornbychapman, we’re committed to protecting and respecting your privacy. This policy explains when and why we collect personal information about people who engage with our services, how we use it, the conditions under which we may disclose it to others, and how we keep it secure. We may change this policy from time to time, so please check this policy occasionally to ensure that you’re happy with any changes. By engaging with us (either by applying for a job we’re advertising, or getting in touch with our business) you’re agreeing to be bound by this policy. Any questions regarding this Policy and our privacy practices should be sent by email to our Data Protection Officer, Karen MacDougall – karen@hornbychapman.com.

Who are we?
We’re HornbyChapman Limited, a recruitment business dedicated to finding people jobs in the financial services sector globally. HornbyChapman is a Limited Company (no. 5994664). The registered address is 89 Worship Street, London EC2A 2BF.

How do we collect information from you?
We obtain information about you when you engage with us. For example:

• When you apply for a job we are advertising either on our own website or on our partner job-board websites

• When you register with us or enquire about our services

• When you meet with us in person

What type of information do we collect from you?
The personal information we collect from you commonly includes the type of information that’s likely to be listed on your CV, for example, your name, address, contact information, educational and work history. We are likely to ask you for additional details to help you find a job and help us comply with our regulatory undertakings. For example, the type of job you are looking for, your previous salary, your nationality and your ability to work in the UK or another country (for which you will be asked to provide documentary evidence). We may also ask you to provide us with additional sensitive data, such as your age, ethnicity, religious beliefs, gender, sexual orientation and any disabilities. The reason we ask for this sort of data is to assist us in monitoring our diversity and inclusion statistics. This information is not used in any other way. Also, it is entirely optional if you wish to share this information with us and by doing so help us promote diversity and inclusion across our services.

How is your information used?
We may use your information to:

• help you find a job by notifying you of new vacancies

• share with our clients to help you find a job (although your specific consent will be obtained on a case-by-case basis)

• send you communications in relation to your job search and recruitment services

• send you communications in relation to hiring new talent (our clients only)

• carry out our obligations arising from any contracts entered into by you and us

• seek your views or comments on the services we provide

• notify you of changes to our services to you

Due to the long-term nature of job searching and the relationship with our clients, our retention period for personal information is five years. This period begins from the last time we have had contact from you. In some cases, we are legally required to hold some types of information to fulfill our statutory obligations, although it is unlikely this will exceed five years.

Who has access to your information?
We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.

Our clients
To find you a job, it perhaps comes as no surprise we need to share your details with our clients, who may ultimately go on to be your future employer. This may involve uploading your data onto our clients’ websites, recruitment systems or sharing via email. In all cases your consent is obtained and recorded on a specific case-by-case basis. Our clients may choose to contact you directly following this, to request additional information and share their own privacy policy with you.

Our 3rd party providers
HornbyChapman uses third-party providers that provide us with solutions allowing us to perform our services. They provide applications such as our email, database, electronic forms, website, and finance systems. These third parties will not control your data, nor will they have non-solicited access to it. They do, however, assist us in providing the online security protections that keep your data safe and secure. Hornbychapman performs regular risk assessments and monitoring of the effectiveness of the online protections our third parties provide. We may transfer your personal information to a third party:

• as part of a sale of some or all our business and assets to any third party

• or as part of any business restructuring or reorganisation

• or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation

• or to enforce or apply our terms of use

• or to protect the rights, property or safety of our supporters and customers.

• However, we will take steps to ensure your privacy rights continue to be protected.

Your choices
You have a choice whether you wish to receive information from us and continue to use our services. If you do not want to receive communications from us about our recruitment services, you can request at any time to be removed from our systems and exercise ‘the right to be forgotten’. Similarly, you have the right to request details of data we currently hold by making what is known as a ‘subject access request’, to which we will respond to within one month. Any requests can be made by emailing us at karen@hornbychapman.com or by writing to HornbyChapman Limited, 89 Worship Street, London EC2A 2BF. Please ensure you mark your correspondence ‘Right to be Forgotten’ or ‘Subject Access Request’. We do not intend to contact you for direct marketing purposes by email, phone or text message. We will only contact you as identified in the ‘How your information is used’ section above.

How you can update your information
The accuracy of your information is important to us. If any of your information changes, or any of the information we hold is inaccurate or out of date, please email us at karen@hornbychapman.com or write to HornbyChapman Limited, 89 Worship Street, London EC2A 2BF.

Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it’s treated securely. Your details are most likely to be transmitted to us over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

Transferring your information outside of Europe
As part of our services, some of the information which you provide to us, on occasions, may be transferred to countries outside the European Union (“EU”). For example, this may be when we need to perform a pre-employment background check if you have lived and worked overseas and we need to verify this. If so, your specific consent will be obtained prior to us doing so. When selecting software suppliers, we ensure we work with vendors who operate servers within the UK and EU, as it gives us certain assurances your data will be protected by the same data protection laws. However, there could be rare occasions when we need to engage with providers who, from time to time, are in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storage or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken, with the aim of ensuring your privacy rights continue to be protected as outlined in this policy. If you use our services while you are outside the EU, your information may be transferred outside the EU to provide you with those services.

Making a complaint
In the event you wish to make a complaint about anything regarding the processing and retention of your data, please in the first instance contact our Data Protection Officer, Karen MacDougall (karen@Hornbychapman.com). If you’re unhappy with the response from our DPO, or if you need any advice, you should contact the Information Commissioner’s Office (ICO) on the number below: ICO helpline: 0303 123 1113

Review of this policy
We keep this policy under regular review. This Policy was last updated in May 2018