1. WHAT THIS PRIVACY NOTICE COVERS
This Privacy Notice provides information about personal data which is processed by a company or companies within the Prax Group of companies (“Prax Group” or “we”) in relation to individuals who apply to work for a Prax Group company, or who attend a recruitment event. This includes prospective employees, interns and temporary external staff.
For individuals who are successful in their application for employment, temporary external employment or internship, the Internal Privacy Notice will apply.
A candidate privacy notice complies with the retained EU law version of the General Data Protection Regulation (EU) 2016/679) (UK GDPR). It notifies prospective employees, workers and contractors about the personal data that the employer proposes to hold relating to them, how they can expect their personal data to be used and for what purposes.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2. PERSONAL DATA WE PROCESS ABOUT YOU
This Privacy Notice explains what personal data we process about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as your rights and the options you have regarding your personal data and where to go for further information. This is in accordance with the Data Protection Act 2018, the UK adoption of General Data Protection Regulation (GDPR) and other applicable data protection regulation.
3. DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will 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
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae (CV) and covering letter
- The information you have provided on our application form, including name, title, address, personal contact information, gender, employment history, and qualifications
- Whether you have the legal right to work in the country in which you have applied
- Any information you provide to us during an interview
- Results of interviews and assessments
Sensitive Data:
For the purposes of recruitment, special categories of data (“sensitive personal data”), including personal data regarding health data, may be processed for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems.
We may also collect, store and use the following types of more sensitive person information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
5. HOW YOUR PERSONAL INFORMATION IS COLLECTED
We may collect personal information about candidates from the following sources:
- You, the candidate
- The relevant recruitment agency, from which we collect the information provided to the recruiter in your Curriculum Vitae
- Disclosure and Barring Service (DBS) in respect of criminal convictions
- Credit Reference Agencies
- Your named referees, from whom we collect the following categories of data: your roles and titles, your dates of employment or engagement, your attendance and your disciplinary record
- Data from publicly accessible sources
6. WHY WE PROCESS YOUR PERSONAL DATA
We use your personal data for the following purposes:
- Assess your skills, qualifications, and suitability for the work / role
- Carry out background and reference checks, where applicable
- Communicate with you about the recruitment process
- Keep records related to our hiring processes
- Comply with legal or regulatory requirements
We only process your data where there is a legal basis to do so. It is in our legitimate interests to decide whether to appoint you to the role, since it would be beneficial to our business to appoint someone to that role.
Where processing is based on you giving your consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
We need to process your personal information to decide whether to enter into a contract of employment with you.
Screening of Applicants:
We may carry out screening of applicants to whom we intend to make a direct offer of employment, and prior to any offer being confirmed. This is for the purposes of:
- verifying the information that an applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No action will be taken until the applicant gives consent that the verification can take place.
- screening applicants against publicly available or government-issued sanctions lists and media sources. This is to comply with legal and regulatory obligations, to protect the Prax Group’s assets, employees, and temporary external staff and specifically to ensure that the Prax Group can comply with anti-money laundering and/or bribery and corruption laws and other regulatory requirements.
We do not use your personal data for automated decision-making or profiling.
7. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
8. DATA SHARING
We will only share your personal information with recruitment and search agencies for the purposes of processing your application. All our third-party service providers and other entities in the Prax 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.
9. TRANSFER TO OTHER COUNTRIES
Where your personal data has been transferred to companies within the Prax Group and/or authorised third parties located outside of your country, we take organisational, contractual and legal measures to ensure that your personal data is processed for the purposes mentioned above and that adequate levels of protection are in place to safeguard personal data. These measures may include data sharing/data transfer agreements for transfers within the Prax Group, and EU-approved transferred mechanisms for transfers to third parties.
10. SECURITY OF YOUR PERSONAL DATA
The Prax Group is committed to safeguarding your personal data. We have implemented physical security, cybersecurity technology and policies with the objective of protecting your privacy, unauthorised access to your personal data, improper use, alteration, or disclosure. We update and review these measures on an ongoing basis.
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. 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.
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 aresubject to a duty of confidentiality.
11. HOW LONG WE KEEP PERSONAL DATA FOR
We hold personal data of unsuccessful applicants for a maximum of 6 – 12 months after the recruitment process for the role you have applied for has been completed.
We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
Information may be held for a longer period of time where there is a legal or regulatory reason to do so (in which case, it will be deleted once no longer required for the legal or regulatory purpose).
If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Internal Privacy Notice.
12. SOCIAL MEDIA
If you choose to interact with Prax through social media on a Prax administered social media page such as X (formerly Twitter), Facebook, LinkedIn or YouTube, your personal data (such as your name, your profile picture and the fact that you are interested in the Prax Group) will be visible to all visitors, depending on your privacy settings on the relevant social media platform, and will also be visible to Prax. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. Prax does not track your activity across the different social media sites that you use. If you send a message to Prax via any messenger service on a social media platform, please note these messages will be held on file and shared internally by Prax via e-mail to ensure swift resolution. These messages will be retained as long as is necessary and in line with the Prax Data Retention Policy.
Additionally, and to the extent the Prax Group is jointly responsible with a social media platform of a Prax social media page, Prax will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Prax social media pages. For more information on how your personal data is processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
13. YOUR RIGHTS IN RELATION TO PERSONAL DATA
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- access to your personal data;
- correction or deletion of the personal data (but only where it is no longer required for a legitimate business purpose);
- that you no longer receive marketing communications on behalf of the relevant Business Counterparty, Supplier or Business Partner;
- object to the processing of your personal data;
- that the processing of your personal data is restricted;
- that you receive personal data that you have provided to the Prax Group, in a structured, digital form to be transmitted to another party, if this is technically feasible;
- 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. To withdraw your consent, please contact us using the contact details below. 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.
14. ENQUIRIES, CONCERNS OR COMPLAINTS
If you have any queries or complaints regarding your personal data, please contact: privacy@prax.com.
You can also contact the Data Privacy Officer (DPO) at: The Prax Group, York House, 45 Seymour Street, London W1H 7JT, United Kingdom.
If you are not satisfied with our handling of personal data, you have the right to submit a complaint to your local data protection authority or the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
15. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is subject to change over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in October 2024.
