This notice sets out how SEI Investments (Europe) Limited (“SEI”, “we”, or “us”), being the entity that will process personal data (as a data controller) as part of your application and recruitment process and the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice. We are registered in the UK and our registered address is at 1st Floor Alphabeta, 14-18 Finsbury Square, London, United Kingdom, EC2A 1BR and our company registration number is 03765319.
Personal data that we collect about you
Our policy is to collect only the personal data necessary for agreed purposes and we ask our candidates only to share personal data where it is strictly needed for those purposes.
We process many categories of personal data as part of your application for employment and onboarding (where applicable):
Information that you provide to us or one of our affiliates. Generally, we collect personal information directly from you when you apply for a role with us, this includes:
• Contact details, such as name, postal address, telephone number and email address
• Information about your job, appraisals, performance, compensation, benefits, training
• Education, information obtained from references or background checks
• Health, disabilities, absences
• Nationality, visa, right to work permit information (e.g. passport, driving licence)
• Financial and transactional data, such as bank account information
• Other personal data, such as date of birth, National Insurance numbers
• Any data relating to you that could identify you from that data (or from that data and any other data in the Company’s possession).
• Information we collect or generate about you.
This includes:
• work-related details such as your job position, contact details, performance at work, absences, pay and benefits information, service history, a copy of your employment agreement, passport details, photograph, health information, pregnancy and/or disability status;
• information obtained through an interview process with you (prior to any applicable offer of employment)
• personal information about you from third parties, including, for example, where a referee provides information about you Information we provide to Human Resources service partners during the onboarding process (where applicable).
This includes:
• Payroll
• Benefit providers
• Background screening
Special Categories of Information
During the process we may inadvertently receive some special categories of personal information about you (e.g. information relating to your racial or ethnic origin, religious or philosophical beliefs, trade union membership, physical or mental health or condition, sexual orientation), where this has been provided by you in your CV or in correspondence with us. We may also process information relating to criminal convictions and offences (e.g. as part of pre-employment screening checks). We will only process special categories of information or information about criminal convictions and offences where we have obtained your explicit consent or where permitted by applicable laws (and then only when necessary for the purposes mentioned above). Where we are processing personal information based on your consent, you have the right to withdraw that consent at any time where there is no other legal basis for the processing.
Uses of your personal data
Your personal data may be stored and processed by us in the following ways and for the following purposes:
• Activities carried out in the course of receiving and assessing candidate applications, including reviewing general applications or applications for specific jobs
• Activities carried out in the course of assessing candidate suitability for roles with us
• Pre-employment screening activities carried out for the purposes of financial, credit history and insurance risk assessments, criminal records checks, screening against external databases and sanctions lists to establish connections to politically exposed persons
• in the course of our search activities, we use personal information that we have collected concerning candidates to identify professional opportunities that we may have and may contact potential candidates from time to time regarding such opportunities.
• market research activities and specific or speculative recruitment related activities. We are entitled to use your personal data in these ways because:
• it is in our legitimate interest to process your personal information in the administration of your application and for general recruitment purposes
• we have legal and regulatory obligations that we have to discharge
• you have provided us with your explicit consent (as mentioned above under special categories of information)
• we may need to in order to establish, exercise or defend our legal rights.
We may rely on one or more of these reasons above to process elements of your personal information throughout the recruitment process.
Disclosure of your information to third parties
When we share data with others, including our affiliates, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
We may share your personal data outside of SEI and our affiliates for the following purposes:
• banks, trustees and administrators of the Company’s pension scheme, payroll administrators, publishers and other relevant parties as part of the background screening process for any applicable offer of employment.
• to governmental, fiscal or regulatory authorities (for example to tax authorities in order to calculate your appropriate taxation, compensation or salary payments).
Transfers of personal data outside the European Economic Area or the UK Where we transfer your personal data outside the European Economic Area (“EEA”) or the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA/UK and that all transfers of personal data outside the EEA/UK are done lawfully. This can be done in a number of ways, for instance, under an agreement which covers the EU/UK requirements for the transfer of personal data outside the EEA/UK, such as The UK Addendum to the EU Standard Contractual Clauses The Company and any Group Company may disclose Personal Information as noted above, including to any of the third parties and for any of the reasons listed above, without further notice to you. You can obtain more details of the protection given to your personal data when it is transferred outside the EEA/UK by contacting us in accordance with the “Contacting us” section below.
Retention of personal data
How long we hold your personal data for will be determined by various criteria including: the purpose for which we are using it (we will need to keep the data for as long as is necessary for that purpose) and any legal obligations (laws or regulation may set a minimum period for which we have to keep your personal data).
Your rights
Subject to any competing legal entitlement or obligation, individuals have a number of legal rights in relation to the personal data that we hold about them:
• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
• where we process personal data based on consent, the right to withdraw your consent to our processing of your personal data at any time and the right to request that we rectify your personal data if it is inaccurate or incomplete
• the right to request that we erase your personal data in certain circumstances
• a right to restrict or object to our processing of personal data and the right to data portability
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, you have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the UK data protection regulator) by contacting the ICO, or by searching their website at https://ico.org.uk/.
Contacting us
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to our Data Protection Officer at:
SEI Investments (Europe) Limited
1st Floor Alphabeta, 14-18 Finsbury Square
London EC2A 1BR
Phone: +44 (0)20 3810 8000
As this privacy notice is updated, the current version will be posted on our website.