DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Questions, queries or feedback you leave, including your email address if you send an email to us
- Information on how you use the site, using cookies and page tagging techniques to help us improve the website
Careers at WLCF Applicants
The following personal information will additionally be collected, stored and used:
- Name, Email Address, Phone Number
- Location and Role applied for
- Cover Letter
WHAT SPECIAL CATEGORIES OF DATA ARE COLLECTED?
We will only, store and use the following “special categories” of more sensitive personal information where they are provided as part of a cover letter or CV:
- Information about your health, including any medical condition, health and sickness records.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
WLCF Ltd will gather information in the following ways:
- Indirectly (through use of www.whitelabelcrowd.fund)
- Directly (where information is provided by you)
For careers at WLCF applicants we may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest (or for official purposes).
Situations in which we will use your personal information
We need all the categories of information in the list above (see the kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated above the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.
- To improve our website
- To answer your queries or feedback
Careers at WLCF Applicants
- Making a decision about your recruitment or appointment
- Determining the terms on which you work for us
- Assessing suitability for fulfilling specific roles with clients
- Checking you are legally entitled to work in the UK
- Making decisions about your engagement
- Ascertaining your fitness to work
- Equal opportunities monitoring
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to progress your application for the position you have applied for.
Change of purpose
We review this notice at least annually or after any significant change to our website, processes, systems or because of government regulations. Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. We recommend that you visit this page from time to time to view any changes that we may have made.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our Policy.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
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 will ensure that third parties respect the security of your data and treat it in accordance with the law.
Where permitted by law, we may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to make a recruitment decision or where we have another legitimate interest in doing so.
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:
Netwise Hosting: Server
How secure is my information with third-party service providers and other entities in our group?
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.
Transferring information outside the EU
When applying for a career at WLCF we may transfer the personal information we collect about you to countries outside the EU in order to perform our contract with you.
We have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:
- Contractual agreement to treat data in line with GDPR.
- Ongoing assurance that third parties comply with and remain within the requirements of the Privacy Shield Framework.
If you require further information about this protective measure, you can request it from firstname.lastname@example.org
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
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. Details of these measures may be obtained by emailing email@example.com
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.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Personal information collected when using WLCF.com will be retained as follows:
Personal Details: 36 Months
Careers at WLCF
Paper and Electronic
Applicant personal details (including sensitive personal data): 36 months
CV and Interview Feedback: 36 months
Recruitment Information: 12 months
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
DIRECT MARKETING COMMUNICATIONS
We may use your data to enable us to send to you post and emails with information about our goods and services that we believe may be of interest to you. You have the right to withdraw from or amend the receipt of direct marketing communications. If you would like to do this simply contact firstname.lastname@example.org and let us know.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us 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.
Request the transfer of your personal information in a portable format to another party. This allows you to take your information from our IT environment to another organisation’s IT environment. The format will be chosen based on the information provided, this is likely to be a generic file format such as CSV.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact email@example.com
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
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.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided 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 firstname.lastname@example.org. 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.
What are Cookies? Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
White Label Crowdfunding Ltd.
10-12 East Parade
Attention: Privacy Officer
You 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.
please contact us at:
White Label Crowdfunding Ltd.
10-12 East Parade
Attention: Privacy Officer
If you are unhappy with the response you receive from us in relation to a complaint, then you have the right to complain to our supervisory authority – the UK Information Commissioner’s office. For further information, please visit www.ico.org.uk.
Date of Last Review: May 2018