Privacy Notice - Applicants
Last Updated: January 2025
This Privacy Notice (“Notice”) describes how Greyhound Capital Management LLP (“Greyhound”, “we”) collects and processes personal data of any persons who register interest or apply for employment or other positions with us (collectively “applicants”, “you” or “your”) and also any third parties whose information is passed to us in connection with any such positions. We might also process personal data of third parties when personal information is provided to us in connection with the application e.g. as a reference.
Greyhound Capital Management LLP is the data controller in respect of your personal data.
Personal data we collect about you
We collect and process personal data of applicants for roles within Greyhound.
Within this Notice, we will set out what types of personal information from applicants and third parties are collected, stored and used, and the purpose or legal basis for this.
The information collected and processed includes the following:
personal details: your title and name, birth name, preferred name, any additional names, gender, nationality, second nationality, civil/marital status, date of birth, age, home contact details (e.g. address, telephone or mobile number, e‑mail), national ID number, immigration and eligibility to work information, driving license, languages spoken; next‑of‑kin/dependent/emergency contact information, details of any disability and any reasonable adjustments required as a result, and your log-in details for use on the applicable Greyhound application website;
recruitment and selection data: skills and experience, qualifications, references, CV, and application, background check information, financial stability checks and reviews on professional and social media. This may also include previous role information (salary / bonus / educational history), and also information about previous knowledge or interactions with Greyhound;
interview and assessment information: interview information and, if applicable, your answers to any test or assessment that you undertake with us, or third parties, in connection with a process;
regulatory information: such as your regulated status or regulatory references; potentially information required to be disclosed in a Senior Manager and Certification regime questionnaire such as prior bankruptcies, litigation history, prior regulator interviews, subpoenas or information requirements received; records of registration with any regulatory authority;
third party details: such as the names and details of your referees or emergency contact. (Before you provide us with any third party data, you should make sure you are permitted to so and, where required by applicable data protection laws, have obtained permission before sharing such data with us);
data relating to criminal convictions or offences: such as criminal background checks and/or criminal history;
equality and diversity data: where permitted by law and provided voluntarily, data regarding gender, age, race, nationality, religious belief and sexuality (stored anonymously for equal opportunities monitoring purposes);
any other personal data which you choose to disclose to Greyhound personnel during the course of your application whether verbally or in written form; and
informal opinion data generated in the course of your engagement relating to the administration or management of Greyhound’s relationship with you.
Provision of personal data to Greyhound is generally voluntary, however, we do require certain information in order to comply with our legal and regulatory obligations and in order to perform our contractual obligations to you. For example, if you fail to provide information which is relevant to your legal right to work in your country or your suitability to perform a role which is regulated, we may not be able to employ you in that role or at all.
Why we process your personal data
Your personal data is collected and processed (with your consent where required under applicable data protection laws) for various business purposes, in accordance with applicable laws. Data may occasionally be used for purposes not anticipated by you where permitted under applicable laws. Greyhound always processes your personal data for a specific purpose and processes only the personal data relevant for achieving that purpose. The reasons we process your personal data are set our below:
Applicant attraction, assessment and selection: we require personal data from applicants in order to review and consider your application, assess candidates and make an offer of employment. Data collected may also be used to carry out, where relevant and appropriate, relevant credit checks, right to work verification, criminal record checks, employment history, and to confirm relevant regulatory status and professional qualifications;
Promoting diversity and inclusion and preventing discrimination; and
Meeting our legal and compliance obligations and preventing crime: it is necessary for Greyhound to collect and process your personal data in order that we are able to carry out necessary regulatory compliance checks, make disclosures and comply with requests from public authorities, regulators or governmental bodies. We also require the personal data in order to conduct and prevent fraud and other crime. We may also gather data in order to enforce our legal rights in connection with any legal claims made by, against or otherwise involving you.
We may also process data for other purposes, which we will notify to you from time to time, and where required by applicable law, obtain your consent.
How we process your personal data
We will collect your personal data directly from you, via the online application process, through emails, or via other online platforms. In addition, further information is often generated by internal sources (through assessments or interview feedback, or you may have been referred to us by an existing Greyhound employee). Personal data about you may also be collected from recruiters, other appropriate third parties (like referees or talent consultants), or from materials available online through platforms such as LinkedIn.
Legal bases for processing
In the UK and EU, it is required that the legal bases for processing personal data must be listed. The legal bases for processing your personal data are set out below:
necessary in order to enter contracts with your relating to your engagement with us;
necessary in order to comply with our legal obligations under certain laws;
necessary for the legitimate interest of Greyhound, where these are not overridden by your interests or fundamental rights and freedoms (Greyhound’s legitimate interests may consist of working with the firm’s regulators to meet their requirements, or, for example, exercising our fundamental rights and freedoms e.g. to conduct a business and right to property); and
Where the above bases do not apply, processed with your consent.
(For the avoidance of doubt, we do not rely on your consent as a basis for processing your personal data in the EU, the UK or Switzerland, except in certain limited situations. For Singapore, we will obtain your consent to the collection, use, disclosure or otherwise processing of your personal data).
Data sharing
Within Greyhound, your personal data can be accessed by or may be disclosed on a need-to-know basis internally to Greyhound staff, including managers and team members.
We may also share your personal data with our affiliates for the purposes described in this Notice.
Personal data may be shared with service providers that perform services on our behalf, such as analytics providers and hosting providers, and also with recruiters and talent consultants. In accordance with applicable law, we have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf for the purposes described in this Notice or comply with applicable legal or regulatory requirements.
In addition, we may disclose personal data about you (a) if we are required or permitted to do so (i) by law or legal process, for example due to a court order or a request from a law enforcement agency, or (ii) to establish, exercise or defend our legal rights, or (iii) by our regulator(s) or any applicable regulations; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, or (d) in connection with business continuity purposes.
Security of Data
Greyhound uses a variety of technical and organisational methods to secure your personal data in accordance with applicable laws. We are committed to protecting the security of the personal data you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk. We require our vendors and suppliers to keep the personal data that we provide to them secure, both in transit and once received by them. This includes encryption, where appropriate.
Data Transfers
We may transfer the personal data that we collect about you to recipients in countries outside the UK. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.
Greyhound complies with all applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the UK. In all such cases, we will only transfer your personal data if:
The country to which the personal data will be transferred has been granted an adequacy determination in accordance with UK law; or
We have put in place appropriate safeguards in respect of the transfer to ensure an adequate level of protection for the personal data transferred, for example the EU Standard Contractual Clauses or the UK International Data Transfer Agreement.
You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described below.
Data retention
Your personal data is retained for varying time periods to assist us in complying with legal and regulatory obligations, or to enable compliance with any regulator requests, for instance, or for other legitimate business reasons.
We retain your personal data for the period of time required for the purpose for which it was collected or where required to comply with legal or regulatory requirements.
Your rights and choices
Subject to applicable law, you may have the following rights in relation to personal information that we hold about you:
request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
that we rectify or update your personal information that is inaccurate, incomplete or outdated;
that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, (for example, a request that we update a copy of your personal information); where you have given Greyhound consent to process your personal information, to withdraw your consent;
that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances; and
object to certain of our data processing, such as for direct marketing purposes.
If you wish to exercise any of your data protection rights or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed in the “How to contact us” section below.
If you consider that we have processed your personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the Information Commissioner’s Office.
How to contact us
If you have any questions about this Notice, or you would like to exercise any of your rights, please let us know by contacting us using any of the methods below:
By email: compliance@greyhoundcapital.com
In writing: Greyhound Capital Management LLP
25 St. James Street,
London
SW1A 1HA
Attention: Chief Compliance Officer