Employment applicant privacy notice
This Privacy Notice tells you how The London Metal Exchange and LME Clear Limited ("LME", "we" or "us") process your personal data. It also describes your data protection rights, including a right to object to some of the processing which LME carries out. More information about your rights, and how to exercise them, is set out in the Your Choices and Rights section.
We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
This Privacy Notice applies to all applicants for employment with LME and, where applicable, to applicants for consultancy positions with LME.
What personal data we collect
We may obtain your personal data because you have submitted an application for a position with LME (either directly or through a recruiter). This personal data includes, but is not limited to your name, contact details, email address, interests and aspirations, gender, nationality, former employer(s), name of the employee referring you, academic background (including professional qualifications) and Curriculum Vitae (CV). We will hold, use and process that personal data in accordance with the terms of this Policy.
Please do not include any sensitive personal data as part of your application, i.e. information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality as well as information regarding criminal convictions. If we do require this information, and more particularly information regarding criminal convictions, in connection with your application, we will inform you separately.
Please ensure you have the consent of any referee whose details you provide alongside your application for us to use their personal data as outlined in this Policy.
On occasion, we receive personal data from third party sources, such as if we receive details of a certification or training you obtained, or where we receive feedback concerning your performance.
Verification and staff checks
For some positions, it will be necessary for us to verify the details you have supplied (for example in relation to your identity, academic credentials or your employment history) and /or carry out pre-employment checks (for example in relation to previous criminal convictions or financial standing). The level of required checks will vary by position and will usually be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.
Why we collect, use and store this personal data
We collect, use and store your personal data for the reasons set out below.
We may process your personal data for the following purposes:
- As required to operate our business and to pursue our legitimate interests to: make informed decisions on recruitment and ensure your suitability for the role or to keep you in mind for future roles; answer your enquiries; improve our recruitment processes and activities; manage our IT systems; and to conduct group administration.
- In order to comply with applicable laws and protection of our legitimate business interests and legal rights including but not limited to, use in connection with legal claims, compliance, regulatory investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation).
We may also ask for your consent to carry out certain verification and staff background checks where this is required in connection with your role. Where we do process data based on consent, your consent can be withdrawn at any time.
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on our balancing tests by contacting us using the details set out later in this notice.
If it is mandatory for you to provide data for these purposes, we will make this clear at the time the data is collected and will also explain what will happen if you do not provide the data.
How we share your personal data
We share some of your personal data with LME's parent company, Hong Kong Exchanges and Clearing Limited who store it on shared IT systems based in Hong Kong. Please note that Hong Kong does not have equivalent data protection laws to those in the EU.
Your personal data will also be shared with companies providing services under contract to LME, such as help desk providers, IT hosting and/or IT maintenance providers, and service providers which help us with pre-employment screening and interview testing. Some of these companies are also in countries outside the EU which do not have equivalent data protection laws.
When we transfer your data within the HKEX group, we make use of standard contractual data protection clauses, which have been approved by the European Commission. When we transfer your data to organisations outside the HKEX group we may use these clauses. We may also transfer your data to organisations in the US who participate in the EU-US Privacy Shield or which have corporate rules in place to protect your data, which have been approved by EU data protection authorities. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.
Your choices and rights
You have the right to ask LME for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to LME processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.
If your application is successful, we will retain your personal data for the period of your employment in line with our employee privacy notice (which will be provided to you separately).
If your application is unsuccessful, your details will be deleted from the LME recruitment systems after 9 months from the date you submitted your details to LME. You can request that we stop holding your details for this purpose at any time by contacting us, see the Contact Us section.
Updates to this Privacy Notice
This Privacy Notice may be updated periodically. We will update the date at the top of this Privacy Notice accordingly and will also actively advise you of specific data handling activities or significant changes to this Privacy Notice, as required by applicable law.
If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our personal data processing, please contact us at 0207 113 8799.
16 May 2018