Candidate privacy policy
We will collect and process personal data in line with our legal and regulatory obligations for the purposes of recruitment and selection. As a “data controller”, this privacy notice describes how we collect and use personal and special category information about you during the recruitment process.
Who we are
This notice covers candidates applying for roles with either Nucleus Group Services Limited (“Nucleus”) or Third Financial (“Third”). “We”, “our” or “us” refers to both Nucleus and Third collectively.
Third includes Third Platform Services Ltd, Third Financial Software Ltd and TPS Offshore (Jersey) Ltd.
What information we use and collect
We will only use your personal information when the law allows us to, and this will be:
- Where we need to comply with a legal, contractual, or regulatory obligation.
- Where we have a legitimate business reason, and this doesn’t override your rights to privacy.
- Where you provide consent to the processing for the purposes of recruitment.
How is your personal information collected
As part of the application process, we will ask you to complete an application form as well as uploading your CV to our recruitment system.
The information we will ask you for includes:
- Personal details such as name, title, address, telephone numbers, personal email address.
- Recruitment information, such as copies of right to work documentation, and other information included in a CV or the application form as part of the application process.
We may also receive information about you from other third parties, including recruitment agencies. Applicants can contact a member of the People team for detail on who has provided this data to us.
Information about criminal convictions
We will collect information about any criminal convictions you may have during the vetting stage of the recruitment process with roles being subject to satisfactory references and other checks such as right to work and credit checks. These vetting checks will be carried out by a third party. We are entitled to carry out regular criminal record checks to satisfy ourselves that you do not have criminal convictions which would make you unsuitable for a role. In particular:
- Certain roles require a high degree of trust and integrity as they involve dealing with, for example, high value investor money, vulnerable investors and investor data, so we would seek a basic disclosure of your criminal records history.
- In addition, we have a duty of care to our existing staff population and must always endeavour to meet this.
The Nucleus Group Appropriate Policy Document details how we will process any criminal conviction data we collect. You can request a copy of the document by contacting the Data Protection Officer dataprotection@nucleusfinancial.com.
How we will use information about you
- We will use any information you provide in the following ways:
- To assess your suitability for a role you have applied for, and to move your application through the various stages of the recruitment process, including interview and offer of employment.
- To review and monitor who and where the applications are coming from, in line with our commitment to diversity and inclusion. This data will enable us to make changes to our recruitment approach as necessary.
- To help us develop and improve our recruitment process.
- Automated decision making
We do not use any automated decision making as part of our recruitment process. Final recruitment decisions are made by hiring manager(s) and members of our People team. We take account of all the information gathered during the application process before a decision is made.
Use of Artificial Intelligence (AI)
At Nucleus, we use software and tools containing Artificial Intelligence (AI) to enhance business efficiency and support analytical purposes. AI may be employed in the following ways:
- We use third party software to manage our recruitment processes. This may include the use of AI for generating summaries, reports and analytics. This use of AI is to automate processes, and any personal data processed through AI will only be used in compliance with this privacy notice and relevant data protection legislation.
- Where you have participated in meetings, whether in person or remotely (e.g. via Teams), we may use AI to assist in summarising the discussions and analysing the tone or sentiment of the meetings.
Your personal data will only be used within the scope of the original purpose for which it was collected, and AI tools will be applied in a manner that upholds your rights under data protection laws.
Data retention
- If your application is rejected at the CV review stage, your personal information will be retained for 90 days following the date of application, after which it will be deleted from our system unless you have consented to us retaining it for longer.
- If your application progresses beyond the CV stage, your personal information will be retained for 90 days following the closure of the vacancy, after which it will be deleted unless you have provided consent for extended retention.
- Where you provide consent, we will retain your application information for 12 months to allow us to contact you regarding future vacancies.
After this period, your information will be deleted and will no longer be processed for recruitment purposes.
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.
Your rights
You have the right to:
- Request access to your personal information.
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information.
- Request the restriction of processing of your personal information.
- Request the transfer of your personal information to another party.
- Withdraw or amend any consent that you’ve given us to collect, process or transfer your personal information.
- Lodge a complaint with the Information Commissioner’s Office (see ICO contact page).
You can exercise these rights by contacting:
Data Protection Officer
Nucleus Financial Platforms Limited
Greenside
12 Blenheim Place
Edinburgh
EH7 5JH
dataprotection@nucleusfinancial.com
In some circumstances, we may refuse your request, for example, we may refuse to delete information if we need to retain it for legal reasons or in order to defend a claim. We will let you know if your request has been refused and explain the reasons to you.