We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Our website is not intended for use by children and we do not knowingly collect or use personal information relating to children.
This policy should be read in conjunction with our Data Protection Privacy Notice for Candidates and our Cookie Policy, these are both available on our website.
This privacy policy does not:
(a) apply to our processing of personal data for engaged consultants or employees of JPSB whose data shall be processed in accordance with our Data Protection Policy which is available by request to our Data Privacy Officer, at privacy@jpsbgroup.com
(b) apply in respect of our provision of services which at all times shall be governed by our terms of business or other contractual documentation.
1. Who are we?
1.1. Our website is operated by JPSB Group, through JPSB Limited with company number 04156972 and registered office at Dawson House, 5 Jewry Street, London, United Kingdom, EC3N 2EX (“we”, “us”, “our”).
1.2. We are a consultancy and support business for the investment management community. For more information please see: https://www.jpsbgroup.com/services/ .
1.3. In order to work with our consultants and our clients we may collect, use and are responsible for certain personal information. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
1.4. If you wish to contact us, please send an email to privacy@jpsbgroup.com or write to the address above.
2. Our website
2.1. This privacy policy also relates to your use of our website, https://www.jpsbgroup.com (“our website”).
2.2. Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional services or products available to you. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.
3. What Is Personal Data?
3.1. Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
3.2. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
3.3. The personal data that we use is set below.
4. What personal information we collect and why
4.1. You are under no obligation to provide us with data. However, if you do not provide certain information, we will not be able to progress any application with us.
4.2. We may collect personal information about you when you access our website, register with us, submit CVs, contact us, send us feedback, purchase services via our website or otherwise, post material to our website and complete customer surveys or provide us with information.
4.3. We collect this personal information from you either directly, such as when you submit CV’s, register with us, contact us or indirectly, such as data you have published on business social media, on your browsing activity while on our website (see ‘Cookies’ below).
4.4. The personal information we collect about you depends on the particular activities carried out through our website or otherwise. This information may include:
4.4.1. Your name and contact details (i.e., address, home and mobile phone numbers, email address);
4.4.2. Your date of birth;
4.4.3. Your bank account and payment details;
4.4.4. details of any feedback you give us by phone, email, post or via social media;
4.4.5. information about the services we provide to you;
4.4.6. Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
4.4.7. Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
4.4.8. Details of any referees.
4.4.9. Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
4.4.10. Information regarding your academic and professional qualifications;
4.4.11. Information regarding your criminal record, in a criminal records certificate (CRC) or enhanced criminal records certificate (ECRC);
4.4.12. Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
4.4.13. Information relating to your health;
4.4.14. A copy of your driving licence and/or passport.
5. How do we use your personal data?
5.1. We need to collect and process data in order to progress any application to join our network of consultants, or for us to find you work with our clients, or to help you and our client verify that you are eligible to work with that client.
5.2. We may process your personal data for the purposes of progressing an application to join our network of consultants and fulfilling our obligations to you. This may include, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you, and developing and managing our services and relationship with you and our clients.
5.3. In some cases, we may be required to collect and process your data for the purpose of investigating, reporting, and detecting crime, and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
5.4. The legal bases we rely upon to offer our services to you are:
5.4.1. Your consent (e.g. to register as a candidate (either for yourself or your service company, manage our relationship with you);
5.4.2. Where we have a legitimate interest (e.g. managing our database and keeping work records up to date, providing work finding services to you and our clients, and contacting you to seek your consent where it is needed);
5.4.3. To comply with a legal obligation that we are subject to (e.g. in order to check your entitlement to work in the UK or elsewhere or to comply with safeguarding requirements).
5.5. We will only use your personal data for the purposes for which it was originally collected, unless we reasonably believe that another purpose is compatible with those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in clause 1.
5.6. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
5.7. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
6. How long will we keep your personal data?
6.1. We will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it and in line with our Data Retention Policy
6.2. Different laws may also require us to keep data for different periods of time.
6.3. We may also keep records in respect of payments made. These records are retained for as long as is legally required by HMRC and associated tax legislation.
6.4. Where we have obtained your consent to process your personal and sensitive data, we will do so in line with our Data Protection Policy or any relevant Privacy Notice. Upon expiry of the period to which you have consented, we will seek further consent from you. Where consent is not granted, we will not continue to process your data.
7. How and Where Do You Store or Transfer My Personal Data?
7.1. Data is stored in a range of different places, including on your application record, in our consultancy management systems and in other IT systems (including our email system).
7.2. We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
7.3. We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
8. Do You Share My Personal Data?
8.1. We may process your personal data and/or sensitive personal data with the following recipients:
8.1.1. Our wider group companies;
8.1.2. Our clients;
8.1.3. Any applicable legal or government authorities;
8.1.4. Previous employers (e.g. in respect of references);
8.1.5. Third party payment service providers;
8.2. When your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
8.3. If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
9. How Can I Access My Personal Data?
9.1. If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.
9.2. All subject access requests should be made in writing and sent to the email or postal addresses shown in clause 1 of this policy.
9.3. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
9.4. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept informed of our progress.
10. How we keep your personal information secure
10.1. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
10.2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do.
11. Cookies and other tracking technologies
11.1. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
11.2. For further information on our use of cookies, please see our cookie policy using the link above.
12. Your legal rights
12.1. You have the right to:
12.1.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
12.1.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.1.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
12.1.4. Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
12.1.5.1. If you want us to establish the data’s accuracy.
12.1.5.2. Where our use of the data is unlawful but you do not want us to erase it.
12.1.5.3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
12.1.5.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.1.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
12.1.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
13. How Do I Contact You?
13.1. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the details found in clause 1 of this policy.
14. Changes to this website privacy policy
14.1. This privacy policy was last updated in March 2021.
14.2. We may alter this privacy policy at any time. Any such changes will become binding on you on your first use of our website after the changes have been made. You are therefore advised to check this page from time to time.
14.3. In the event of any conflict between the current version of this privacy policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
14.4. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
15. How to complain
15.1. We hope that we can resolve any query or concern you raise about our use of your information.
15.2. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.
