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ABI Candidate Privacy Notice and Summary of Legitimate Interest

For job applicants

This notice describes how the ABI collects and uses personal information about you during the application and recruitment process, in accordance with the General Data Protection Regulation (GDPR) and UK data protection laws. This notice may be amended or updated at any time. 

The personal information we hold about you

We may collect store and use the following categories of personal information about you: 

  • information relevant to our recruitment decision, including CVs, application forms, interview notes, results of pre-employment checks, references; 
  • information relating to your right to work: including passport information, visa details, immigration permissions, travel information; 
  • information relating to reasonable adjustments which may be required to accommodate a disability; 
  • equal opportunities monitoring information.

We collect this personal information either directly from you or from third parties including employment agencies, former employers, other referees, qualifications bodies, credit reference agencies or other background check agencies or publicly available information eg on LinkedIn.

How we use your personal information

We process this information for the following purposes:

  • recruiting employees who have the appropriate skills, qualification and experience for each role;
  • ensuring employees have the right to work in the UK;
  • complying with our duty to make reasonable adjustments;
  • monitoring equality of opportunity and diversity in the recruitment process.

We process your personal information because it is necessary for our legitimate interests of operating our business efficiently; maintaining standards of service to our members and improving diversity of opportunity, or because it is necessary for us to comply with our legal obligations.

In addition, where we process any information which falls within "special categories", namely health information, trade union information and information about race, ethnic origin, religion or sexual orientation, this is because it is necessary for complying with our employment law obligations, or for exercising our employment law rights, or for monitoring and improving equal opportunities. In certain circumstances we may process special categories of personal information where it is needed in relation to legal claims, or in order to protect your interests where you are not capable of giving consent.

If you fail to provide certain information when requested, in some circumstances we may not be able to continue with the recruitment process.

Automated means

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

We share your personal information with third party service providers who assist with our recruitment process. The providers include:

  • our psychometric testing provider for the Assistant Director and Manager recruitment process.

Transferring information outside the EU

Where needed in order to enable us to achieve the objective of our processing the data as described above we may transfer your personal information to third parties outside the European Economic Area. Where we do so we will only transfer your personal information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personal information, or (b) has agreed (by way of written contract) to provide all protections to your personal information as required by data protection legislation. Any query concerning this should be addressed to the ABI Legal Team, whose details are set out in the final paragraph of this notice.

How long we keep personal information

For successful candidates, we retain personal information from the recruitment process for the periods outlined in our staff data collection notice which we give to new staff on joining.

For unsuccessful candidates we would usually retain recruitment information for a maximum of 2 years, but we may hold the information for longer if we agree with you that your details will be kept on file for future vacancies, or where we have a business reason for doing so (for example, where we may need information in case of legal proceedings).

Your rights and responsibilities

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 recruitment process.

Under certain circumstances, by law you have the right to: 

  • access to your personal information (commonly known as a "data subject access request");
  • rectification of your personal information if it is inaccurate; 
  • object to us processing your personal information where we are relying on a legitimate interest and you believe that your interests override this;
  • temporarily restrict our processing of your personal information, for example where you believe the information may be inaccurate or we may not have grounds for processing it;  
  • erasure of your personal information, if we do not have grounds for continuing to process it;
  • transfer of your personal information to another party;  
  • ask us to send you, or another organisation, certain types of personal information about you in a format that can be read by computer;
  • you can withdraw your consent to our processing your personal information, where our processing is based on your consent.
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Please contact the ABI’s legal Team (philippa.handyside@abi.org.uk) in writing for further information about these rights.

No fee usually required

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 if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Further information

If you have any questions about how we process your personal information, please contact the legal team (philippa.handyside@abi.org.uk). We hope that we will be able to address any questions or concerns you may have. However, you also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Diversity and Inclusion Data Collection at the ABI

Summary of Legitimate Interest (November 2019)

As part of the candidate application process, the ABI requests - on an optional basis - that candidates share the following information as part of their application on our applicant tracking system, Workable:

1. Gender
How the data is used: 

  • To measure our success against our Women in Finance Charter commitments.
  • To understand which job adverts, jobs and job families are most attractive to males and to females and to identify if there is a pattern in this.
  • To measure the success of our attempts to ensure the language of our adverts is balanced in terms of gender.
  • To see where and why we might be losing males/females at each stage of the talent pipeline.

2. Age
How the data is used: 

  • To understand which job adverts, jobs and job families are most attractive to which age group and to identify if there is a pattern in this.
  • To understand if we are missing out on attracting specific age groups.
  • To analyse where and why we might be losing different age ranges at each stage of the talent pipeline.

3. Ethnicity
How the data is used:

  • To understand which job adverts, jobs and job families are most attractive to which ethnic groups and to identify if there is a pattern in this.
  • To understand if we are missing out on attracting specific ethnic groups.
  • To analyse where and why we might be losing different ethnic groups at each stage of the talent pipeline.

4. Disability
How the data is used: 

  • To enable us to meet our commitments under the Disability Confident scheme and offer an interview to candidates who meet the minimum requirements of the role.
  • To measure the success of the Disability Confident scheme
  • To understand if we are missing out on attracting specific disability backgrounds.
  • To analyse where and why we might be losing different disability backgrounds at each stage of the talent pipeline.

5. Sexual Orientation
How the data is used: 

  • To understand if we are missing out on attracting people of a specific sexual orientation.
  • To understand where and why we might be losing people of different sexual orientations at each stage of the talent pipeline.

Overall, collecting this data helps us measure our success against our internal inclusion strategy and continue to build on the work we do to ensure our recruitment and selection processes are as inclusive and bias-free as possible. We also want to understand what data people are most and least willing to share with us to inform our future attraction strategy. This all contributes to ensuring we offer an exemplary and fair candidate experience.

Where the data is held:

Applicant data is retained by the ABI on Workable (the ABI’s third-party, cloud-based Applicant Tracking System) for one year from the candidate applying. After this time, it is automatically and permanently deleted from Workable. Candidates can opt to delete their own data at any time. The ABI also undertakes regular manual cleansing activity to ensure that any remaining candidate data or correspondence on their internal systems is permanently deleted after one year.

A candidate's diversity and inclusion data is not used on an individual basis. Aggregated and anonymised data is extracted from Workable for reporting purposes only. To do this, we request data from Workable. It then goes into a secure API which has been created by the ABI. The API then sends the anonymised data to an Excel document and finally this is funnelled to our business analytics service, Power BI. The individual data originally requested from Workable is permanently removed from the API after a few minutes.

Only five ABI staff members have access to Workable, four of whom are in the HR team and one in the Data and Analytics team. Technically these individuals could access a candidate's personal data on Workable. However, as a matter of course they do not do so and have no reason to do so. We have reviewed our interests in processing the above data as against the impact on the candidate of doing so. We consider that the impact on the candidate is minimal.