EMEA & APAC Candidate Privacy Notice

(1) INTRODUCTION

This Candidate Privacy Notice (“Notice”) applies to candidates for all positions with Jefferies, whether as employees or interns to be engaged directly in Jefferies’ business in EMEA, or others providing services to Jefferies (including consultants, non-executive directors, senior advisors, temps and vendor staff, even though they are not classed as employees of Jefferies) (collectively “Candidates”).

This Notice explains what we do with your personal data from the point at which you apply to work for Jefferies until after the recruitment process has ended (ie, where you accept a position or your application is otherwise closed).  It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.  Your privacy is important to us, and we are committed to protecting and safeguarding your privacy rights.  

For the purpose of applicable data protection legislation, the company responsible for your personal data is Jefferies International Limited for Candidates based in the UK, Switzerland, UAE and Israel , and Jefferies GmbH for Candidates for roles based in continental Europe (“Jefferies” or “us”) (being the data controllers) details for which can be found in section 10. 

This Notice is non-contractual and we may amend it from time to time.  The most recent version of this Notice will be available on Jefferies’ recruitment portal (careers.jefferies.com) as well as in the email footers of the Jefferies recruiting team. 

(2) WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

In connection with your application for work at Jefferies, we collect personal data about you, including:

* Your personal contact details, namely your name, title, home address, telephone numbers, personal email addresses; social media accounts, date of birth, gender and proof of identity;

* Recruitment information about you, including: your CV, your education, qualifications, languages, professional memberships, employment history referee details and details about your remuneration and benefits arrangements with current or former employers.  Depending on your role, we may also ask you to provide details of any investigations, disciplinary matters, litigation or claims in court, tribunal or similar forum, whether brought by or against you or in which you are otherwise involved.

We may also collect, store and use the following “special categories” of personal information (also known as “sensitive personal data”):

  •  Information relating to your nationality or ethnicity will be used to assess whether a work permit and a visa will be necessary for the role;
  •  Information relating to your political opinion where it involves political contributions, fund raising and campaigning for US Federal, State or Local office will be used to ensure compliance with Jefferies’ Political Contribution Compliance Policy as, in some US States, such political activity automatically triggers a ban on entities entering into US state or local government contracts or may result in burdensome disclosure obligations in relation to US government contracts.  In order to assess and manage potential conflicts; such activities require pre-clearance;
  •  Information relating to racial origin or ethnicity, religious or other similar beliefs, sexual orientation, gender identity and Trade Union membership information if volunteered by you in the job application process will be used to ensure meaningful equal opportunity monitoring and reporting in an aggregate form. If you choose not to provide this information, it will not impact on your application;
  •  Any relationships between you and Jefferies’ staff (in particular someone who may consider your application or who may either supervise you or report to you- whether directly or indirectly) for the purposes of avoiding conflicts of interest or the appearance of favouritism/impropriety in the recruitment process;
  •  Health-related information including any medical condition or disability which you disclose to us for the purposes of Jefferies considering reasonable adjustments to the recruitment process, for example whether physical, technological and any other logistical adjustments need to be made during a test or interview to accommodate such condition or disability;
  •  Information about your criminal convictions history may be collected in order to satisfy ourselves that there is nothing which makes you unsuitable for the role or which is prohibited by a regulatory body.

Please note that if you fail to provide (when requested) information which is necessary for us to consider your application, we will not be able to take your application further.

For details of the legal bases that we rely on to be able to use and process your personal data, please see section 6 below.

If we decide to offer you a role, then we will carry out employment background checks, in which case we will manage your personal data in accordance with the EMEA Staff Privacy Notice which will be made available to you at the time of any offer being made. 

(3) HOW DO WE COLLECT YOUR PERSONAL DATA?

There are various ways that we collect your personal information with us.  These include obtaining information about you from the following sources:

  •  Directly from you; 
  •  From Jefferies staff or contacts (including your current and former colleagues) who know you, or third parties providing recruiting services to Jefferies (such as employment agencies or businesses, headhunters or similar);
  •  From third party sources such as LinkedIn and other job sites when we search for potential Candidates and collect your full name, email, work history, and other data included on your profile;
  •  From a third party to carry out employment background check on our behalf during the recruitment/interviewing phase to report on and distil any information about you available through publicly available sources, including online and offline media;
  •  Your named referees (you should ensure you have express consent from your referees for Jefferies to contact them); 
  •  Credit reference agencies;
  •  Competent authorities that are authorized by law to provide criminal records, certificate of good standing or its equivalent (or from publicly accessible sources where criminal checks are prohibited under applicable laws).  

(4) AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

(5) HOW DO WE USE YOUR PERSONAL DATA?

We will use the personal information we collect about you to:

  •  Communicate with you about the recruitment process and to collect your data from you and other sources described in section 3;
  •  Assess your skills, qualifications, and suitability for the role, 
  •  Decide based on your CV, covering letter and the results from any tests, whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to make decisions about employing or engaging you;
  •  Consider and (where appropriate) make reasonable adjustments to our application and/or recruitment process to accommodate any health conditions or disabilities disclosed by you;
  •  Determine the terms on which you may be offered to work for us;
  •  Take up employment references and/or any other employment background check if we decide to offer you the role;
  •  Keep records related to our hiring processes, including when you applied for work for us and the outcome of that application;
  •  Comply with legal or regulatory requirements; 
  •  Where appropriate and in accordance with any local laws and requirements, we may use certain information (ethnic background, gender, gender expression or identity, disability, age, sexual orientation, religion or other beliefs, child care, carer arrangements and/or social-economic background) on an anonymised basis to monitor our compliance with our Equal Opportunities Policy;
  •  In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
  •  All of the information obtained during the application process will only be accessed, and used, for the purpose of progressing your application, or to fulfil legal or regulatory requirements as necessary. 

(6) LEGAL BASES FOR JEFFERIES PROCESSING YOUR DATA

There are a number of different ways that organisations are lawfully able to process individuals’ personal data.  Jefferies will principally rely on the following when processing your personal data: 

  •  It is in our legitimate interests to decide whether to appoint you to work with or for Jefferies since it would be beneficial to our business to appoint someone to that role or work;
  •  We may process your personal data where this is necessary for us to establish, exercise or defend legal claims, or in order to comply with our legal obligations; and 
  •  We will also process your personal data where you give us your consent to do so (for example, to consider you for a role at Jefferies).  

We do not think that any of the above activities prejudice you in any way.  However, you do have the right to object to us processing your personal data in certain circumstances (see section 9 below). 

(7) WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may share your personal data with the following:

  •  Recruitment Process Outsource providers; 
  •  Online recruitment platforms; 
  •  Applicant tracking system providers; 
  •  Affiliates within the Jefferies Group;
  •  Colleagues within Jefferies (where appropriate, this may include colleagues in overseas offices);
  •  Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies, immigration agencies and employment and recruitment agencies and your referees; third parties who we have retained to provide recruitment or background checking services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws; and
  •  Immigration and employment lawyers and consultants.
  •  All our third-party service providers and other entities in the group 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 data for their own purposes.  We only permit them to process your personal data for specified purposes and in accordance with our instructions.

(8) HOW DO WE PROTECT YOUR DATA? 

Jefferies is committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.  We do this by having in place a range of appropriate technical and organisational measures.  These include training for staff on handling personal data as well as measures for appropriately transferring data and dealing with any suspected data breach.

In order for us to carry out the purposes described in this Notice, your personal data may be transferred to those set out in section 7, who may be located outside of your jurisdiction including to our parent company in the United States.  Jefferies makes sure that your data is processed, stored and transferred in a way which is secure and will only transfer data outside of the European Economic Area (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example: 

  •  By way of a data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to data controllers and data processors in jurisdictions without adequate data protection laws; or
  •  Transferring your data to a country which has been found by the European Commission to have adequate levels of data protection; or 
  •  Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer your data to a benefits provider based outside the EEA).

If your application is successful, the information you provide during the application process will be transferred to your employee file and be retained in line with our EMEA Staff Privacy Notice. This document will be made available to you when you join us.

If your application is unsuccessful, we will, unless you object, retain your personal information for a period of 12 months (or for such other period as we may be required to by law) after we have communicated to you our decision about whether to engage or employ you.  We retain your personal information for that period in the event that (i) a further opportunity may arise in future and we may wish to consider you for that; and/or (ii) a legal claim is brought regarding our recruitment process or decision-making so that we can show that we have not discriminated against Candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.  After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. Please note that you can request the removal of your data at any time (see below: Withdraw Consent).

(9) YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Under certain circumstances, you have the following rights:

  •  Access: You may ask us to confirm, and provide copies of, the information we hold about you at any time, and request us to modify, update or delete such information (commonly known as a “data subject access request”). 
  •  Erasure: You have the right to request that we erase your personal data in certain circumstances.
  •  Restrict processing: You have the right to request that we 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).
  •  Correction: You also have the right to request that we rectify any inaccurate or incomplete personal data that we process or control.
  •  Data Portability: If you wish, you have the right to transfer your personal data between data controllers.  To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data.
  •  Object to processing: you may object to processing of your personal information where (i) 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; and (ii) we are processing your personal information for direct marketing purposes.
  •  Withdraw Consent: In the limited circumstances where you have provided, and Jefferies relies on, your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent, please contact your Jefferies recruitment contact or HR representative in the first instance.  Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

if you wish to exercise any of these rights, please contact [email protected] in the first instance.  We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions permissible by law).  

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).  This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee, or otherwise refuse to comply with your request for access if it is clearly unfounded or excessive.  

Where we are legally permitted to do so, we may refuse your request to exercise these rights.  If we refuse your request we will tell you the reasons for doing so

Please note that we may keep a record of your communications to help us resolve any issues which you raise.

(10) CONTACTS

If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the processing of personal data by Jefferies International Limited or Jefferies GmbH (being the data controllers), please contact Jefferies’ European Privacy Office by email [email protected]; or by post to: Jefferies European Privacy Office, Jefferies International Limited, 100 Bishopsgate, London EC2N 3JL, United Kingdom.

You also have the right to lodge a complaint with your local supervisory authority.  In the UK, this is the Information Commissioner’s Office (contactable at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or online via their website: https://ico.org.uk/); for Candidates for positions in continental Europe, this Der Hessische Beauftragte für Datenschutz und Informationsfreiheit in Germany (contactable at Postfach 3163, 65021 Wiesbaden, Germany or via email: [email protected]).  Please contact [email protected] for details of supervisory authorities in other EU jurisdictions where Jefferies has offices.