Privacy

Recruitment privacy notice

We use the term LV= to refer to Liverpool Victoria Financial Services Limited, who will be your employer, if you’re successful within the recruitment process. LV= is the data controller in relation to your data.

LV= is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during the recruitment process, in accordance with the General Data Protection Regulation (GDPR)/UK GDPR and applies to all candidates.

This Privacy Notice is for information only; it is not a contractual agreement.

What information do we collect?

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae and covering letter/email/telephone call;
  
• Any information you provide to us upon registration, application and during an interview or any other part of our recruitment process;
  
• Information you provide in relation to your right to work documentation;
  
• Information in relation to your socioeconomic status
  
• Financial records
  
• The personal details information you have provided to us such as your address information, contact details and national insurance number; and
  
• If offered a role, information you provide in relation to references and address details for us to check your details against fraud prevention databases and DBS checking.

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation
  
• Information about your health, including any medical condition, whether you have a disability and any adjustments that may need to be made in the recruitment process (including details from occupational health reports where obtained); and
  
• Spent and unspent criminal convictions for any Senior Manager role via a Standard DBS under SMCR and unspent criminal convictions for any other role
  
• Bankruptcies and other financial sanctions such as County Court Judgements and IVAs)

We collect this personal information from the following sources:

• You, the candidate;
• Recruitment agencies;
• Search consultants;
• Workmate referral;
• Jobs boards;
• Our employment background check provider;
• Our credit reference agency;
• Your named referees;
• photographs and video, such as security passes and onsite CCTV; and
• Data from third party publicly accessible sources. For example, SIRA and CIFAS professional memberships.

If you are in an FCA/PRA role such as a Senior Manager, Non-Executive Director or a Certified role we may process additional information for regulatory purposes; and details of professional membership numbers or similar.

Why do we process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check your eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from you allows us to manage the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We have a legitimate interest in recruiting candidates who will perform to a high standard and meet the needs of our business.

We may also need to process data from you (including special category data) to respond to and defend against legal claims.

We process health information if we need to make reasonable adjustments to the recruitment process for you. This is to carry out our obligations and so you can exercise your rights in relation to employment law.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for the substantial public interest of equal opportunities monitoring. At point of formal offer, we will also ask for date of birth and legal sex.

We also collect information on socio economic background and gender and use it for equal opportunities monitoring. We have a legitimate interest in ensuring that LV= attracts a diverse range of candidates for the benefit of our business and our employees.

We are obliged to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which would be against FCA and PRA regulations. We use a third party to do this on our behalf and may receive a copy of their report if you have consented for us to do so.  If you do not consent to us seeing the report then we will only receive confirmation of whether or not the result is clear and will not receive any detailed information about your criminal conviction history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the People Team and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. For SMCR roles, the compliance team will also be given access to the data.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, our employment background check provider to obtain necessary background checks, including a criminal record check and our credit reference agency. 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 envisage transferring the personal information we collect about you outside the UK.

How do we protect data?

We take the security of your data seriously. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process unless it is needed in relation to legal claims in which case we will continue to hold it until it is no longer required. After this period, we will securely destroy your personal information in accordance with our data retention policy (although information you have provided for diversity monitoring purposes will be retained in anonymised form).

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

If your application for employment is successful, personal data gathered during the recruitment process (including special category data) will be transferred to your personnel file. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
  
• require us to change incorrect or incomplete data;
  
• require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  
• object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing; and
  
• ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact [email protected]

If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Automated decision-making

Our recruitment processes are not based solely on automated decision-making.