RECRUITMENT PRIVACY POLICY
This Policy contains important information about how Fidelity Worldwide Investment Limited and its associated companies (together "Fidelity") will process your personal data in connection with your application for employment. You are asked to read the Policy carefully before completing the application form. In the event that you have any questions on this Policy, please contact the recruitment team via email - careers@fil.com
WHAT DATA WILL FIDELITY COLLECT ABOUT ME AND WHY?
Fidelity will collect your personal data as may be necessary to process your application for employment as part of its recruitment and selection procedure. This personal data will include (but is not limited to): your name, address and previous addresses, date of birth, employment history, education and qualifications, referees, hobbies, outside interests and memberships of professional bodies etc.
This information may be collected from a number of sources, including interview notes, correspondence and any other documents generated during the recruitment process.
The primary purpose for processing your personal data is to consider your application for employment as part of Fidelity's
recruitment process. In the event that your application for employment is successful, this data may also be retained and
processed for the purpose of the ongoing employment relationship (further information on this processing will be provided
to you as needed). Finally, as explained below, the information which you provide may also be used to assess your suitability
for employment as part of Fidelity's background vetting procedure.
Sensitive Personal Data
Certain information about an individual is known as sensitive personal data. Fidelity may process your sensitive personal data during the recruitment process as follows:-
Criminal convictions and pending proceedings - The Background Vetting Form includes a number of questions relating to
each applicant's criminal convictions and pending proceedings. Fidelity requests and processes this information in order
to monitor and maintain the honesty and integrity of its workforce, particularly in view of Fidelity's range of business
activities (including fund management).
When answering these questions on the Background Vetting Form, you do not
have to declare any criminal convictions which are "spent" under the
Rehabilitation of Offenders Act 1974 unless you are applying for a
position which is covered by the Rehabilitation of Offenders Act 1974
(Exceptions) Order 1975 e.g. as a solicitor or a certified/chartered
accountant. In this case, all convictions (both spent and unspent) and
all pending proceedings must be declared. In the event of a successful
application, appropriate background checks will be undertaken
(including a request for a CRB Disclosure). A criminal record will not
necessarily be a bar to employment with Fidelity. If you have any doubt
over whether you must declare any spent convictions, please contact the
recruitment team via email - careers@fil.com. Please note that this applies to only those applicants who have disclosed a past or present UK address.
Medical conditions and disabilities - During the recruitment process each applicant is asked to provide details of any
medical conditions which may be relevant to the job role in question. Fidelity will process this information in order to
assess each applicant's fitness for the role (in accordance with health and safety legislation). Applicants will also be
asked for details of any disabilities to assist Fidelity to comply with its obligations to disabled persons under the Equality Act 2010 and the Americans with Disabilities Act 1990.
Equal Opportunities Monitoring - Fidelity is an equal opportunities employer and does not discriminate upon the basis of
an applicant's racial/ethnic origin, sex, pregnancy, marital or family status, sexual orientation, religion or belief,
age or disability. Fidelity asks applicants to provide certain information (on a voluntary basis) to assist it to
monitor how its policy on equal opportunities is working in practice. Any information of that nature which you provide will
be stored securely and used only for the purposes outlined in this paragraph. Further details on how Fidelity will use this
information can be found in the introduction to the Equal Opportunities section of the application form.
HOW WILL FIDELITY USE MY PERSONAL DATA?
(a) Recruitment and Selection
Your personal data will be used by Fidelity's HR Department, managers
and other relevant employees during all aspects of the recruitment
process, for example to assess your application, during any interview
and when finalising any recruitment decision.
(b) Background Vetting
Fidelity considers it owes a duty to its customers, clients and
business to ensure that it maintains the highest standards of honesty
and integrity when recruiting for its workforce. As a result, it is
Fidelity's policy to undertake background checks on all applicants who
are offered employment following the recruitment process.
The checks described below will only be undertaken once a successful applicant has signed and returned an offer of employment.
The checks are as follows:-
verification of the applicant's identity;
verification of the applicant's right to work in the UK;
confirmation of consistency in the information provided;
evaluation of employment references over the previous three years (subject to a minimum of two employers);
evaluation of character reference;
verification of highest level of education;
verification of relevant professional certifications, qualifications or affiliations (if any);
verification of any regulatory authorisations (if any).
evaluation of publicly available credit information - i.e. a credit reference check; and
evaluation of publicly available directorship information.
With regard to the last two checks listed above, this is limited to a
"Non-Credit Application Search" of publicly available information such
as the Electoral roll, the Postal Address File, the Association &
Alias File and the Public Information File (which
is based on information from the Registry Trust Ltd, Official Gazettes
and the Insolvency Service). Details of County Court judgments
and bankruptcies are also searched. Please note that this applies to only those applicants who have disclosed a past or present UK address.
If you are offered employment, it is essential that you complete
Fidelity's Background Vetting Form in full and that any information
which you provide on the Form (and otherwise during the recruitment
process) is honest, accurate and not misleading. In the event that a
discrepancy is discovered during the conduct of the background checks,
an applicant will usually be given the opportunity to provide
an explanation. However, all applicants should note that, should such
explanation be unsatisfactory, or if Fidelity otherwise determines
(in its absolute discretion) that the results of the background checks
are a cause for concern, this could lead to any offer of employment
being withdrawn or, where employment has commenced, the immediate
termination of the employment relationship (including summary dismissal
in appropriate cases). In line with the above, all offers of employment
made by Fidelity are expressly conditional upon a satisfactory
background check being completed in relation to each applicant.
WHAT HAPPENS TO MY PERSONAL DATA?
(a) Access and Storage
Documents containing your personal data will be accessed and stored by the following individuals:-
managers and employees of the HR Department for the purposes of the recruitment and selection process - for this purpose, certain details will be stored on Fidelity's electronic Recruitment Database which operates on a world wide basis;
managers and employees of the Investigations & Intelligence Department for the purposes of conducting background vetting checks (in relation to applicants who have accepted an offer of employment); and
managers and employees who are otherwise directly involved in the recruitment process (e.g. line managers involved in the interviewing process).
In all cases, Fidelity takes appropriate
steps to ensure that the documents are stored securely (whether in
hardcopy or softcopy) and that access is restricted only to those
employees with a legitimate purpose.
(b) Transfer to third parties (including other Fidelity Group companies)
If you accept an offer of employment, and have disclosed a past or present UK address, your personal data will be
transferred to Experian Limited as part of the background vetting
checks as described in Section 2(b) above. This transfer takes place
under the terms of an agreement between Fidelity and Experian Limited
which deals with the protection of your personal data.
In a very
limited number of cases, an applicant's personal data may be
transferred to other third parties for the conduct of the background
vetting checks. Such transfer will only take place (i) where an
applicant has accepted an offer of employment; and (ii) he/she has
worked or resided abroad for a significant period within the last three
years. In this event, personal data may be transferred as follows for
assistance with the conduct of the background vetting checks (third
party/relevant location(s)): Kroll PRM, UK and Poland (Europe), FMR
Corporation, Boston (US, Canada), Brooke Consulting, Tokyo (Japan),
Pinkerton Consulting Services, Taipei (Taiwan), Quest Research Limited,
Hong Kong (Far East and Australia), Quest Research Limited, Delhi
(India). In each case, the transfer takes places under the terms of an
agreement which deals with the protection of your personal data.
(c) Retention of personal data
Successful applicants -
If your application for employment is successful, any information which
you have provided during the recruitment process will be retained only
if it is relevant to the ongoing employment relationship. Full details
of how Fidelity processes personal data during the employment
relationship will be provided in due course as needed. Any other
information which you have provided during the recruitment process will
be destroyed within a period of no longer than two years following the
completion of the initial application form. This includes all documents
generated during the conduct of background checks including the
Background Vetting Form, although a summary note of the results of the
checks and any significant points will be retained (along with any
related documents).
Unsuccessful applicants - In the event that your application for employment is unsuccessful
on this occasion, any information which you have provided during the
recruitment process will be retained for a period of no longer than two
years in order to deal with any queries or issues relating to your
application, and to provide background information to any subsequent
application, following which it will be destroyed. The HR Department
may write to an unsuccessful applicant to state that his/her
application form will be retained on file for the purposes of future
recruitment - individuals will be given the opportunity to object to
their application forms being retained for this purpose at the relevant
time.
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