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Application Privacy Notice

If you’re applying for a position with one of the entities, direct or in-direct subsidiaries of the Adam Smith International Ltd group of companies (“ASI”), this privacy notice will help you understand the types of personal information we collect, why we need to process your personal information, how we use it, who we share it with and the rights you have over it.

It applies to personal information that we collect in our capacity as a data controller (the entity that determines why and how it will be processed) from you through the application and recruitment process, either directly from you or sometimes indirectly, for example from an employment agency, job boards, recruitment websites etc.

This applicant privacy notice is aligned with both our Privacy policy and our Code of Conduct.

If you are unsure about anything in this notice please contact people@adamsmithinternational.com for further information.

Personal information we may need to process

Below is a non-exhaustive overview of the categories of personal information that we may process during the recruitment process.

Personal identification: Name, title, gender, country, date of birth, military/veteran status (where required), nationality.

Contact information: Email, phone, address

Network traffic and other online data (collected using cookies and similar technologies): Identification numbers, location, IP address, browsing behaviour, device ID, websites visited, language used.

Account login information: Login ID, other information used to access and/or secure systems and applications including our careers website

Personal information regarding qualifications and career development: Any information contained in CVs and additional documents such as professional certificates, assessment and/or test evaluations, interview notes, application details

Background information: Employment references and, where permitted, information from background[HC8], social media and vetting checks

Sensitive personal information, including special categories: Where necessary and permitted by law, depending on your location we may collect information about your racial or ethnic origin, religious or philosophical beliefs, disability status, sexual orientation, gender identification or other protected characteristics (this allows us to monitor and report on workforce diversity and equality of opportunity). Please note that this type of sensitive personal information is used to comply with legal obligations (where applicable) and, in an aggregated and depersonalised form, for reporting purposes.

Criminal history: Data relating to criminal records and/or alleged offences to the extent that a client, process or law requires us to ask

Compensation and payroll:, desired salary, current salary, compensation and benefits.

Any other information that you volunteer: Feedback, opinions, information provided in emails and letters or conversations

Images and/or videos: Pictures included in your CV, security footage captured during your visit to our offices

Please note that your decision not to provide any of your personal information as required or requested in the context of the recruitment procedure, may affect your ability to participate in the recruitment process.

Information we may collect from other sources

To the extent permitted by applicable laws, in addition to our recruitment channels or careers website, we may also obtain information about you from other sources, such as through your interactions with representatives of ASI during the interview process or from third parties, such as recruiters and former employers (where we are seeking references). We may also obtain information from other websites on the Internet (subject to such third parties’ privacy notices). For example, you may choose to provide us with access to certain data stored by third parties such as business and employment-orientated social media sites or websites.

How we justify our use of your personal information and how we process it

In general, we collect this information to progress your application to ASI (in accordance with our legitimate interests) and to inform you about future opportunities (with your consent). We may also need to process your personal information in order to fulfil legal or regulatory requirements associated with the recruitment process, such as right to work or other immigration checks. Some of the grounds for processing may overlap and there may be several grounds which justify our use of your personal information. Below provides further details on the purposes for which we may process your personal information during the recruitment process.

Progressing your application and internal management of that application

  • Identifying and evaluating applications

  • Assessing skills, qualifications and interest against ASI career opportunities,

  • Setting up and conducting interviews and assessments

  • Evaluating, selecting and recruiting applicants

  • Conducting background checks and assessments as required to comply with ASI policies or permitted by applicable local law

  • Contacting third party references provided by applicant to evaluate previous performances or as otherwise necessary in context of recruitment activities

  • Where applicable, informing the ASI employee that referred the applicant for the job about the status of the recruitment cycle

  • Managing expenses and reimbursements

Responding to your queries and managing our relationship with you

Our talent acquisition teams communicating with you via our recruitment system and/or your chosen communication channel (eg phone call or SMS and email messaging) to:

  • inform you of available vacancies,

  • provide information relating to an application and to fulfil any requests made by you,

  • offer suitable opportunities for employment within ASI, and

  • respond to your ad hoc queries.

Complying with legal obligations arising out of recruitment process

Disclosing personal information to government institutions or supervisory authorities as applicable in all countries in which ASI operates, such as record-keeping and reporting obligations, compliance with government inspections and other requests from government or other public authorities, responding to legal processes such as subpoenas, pursuing legal rights and remedies, and managing any complaints or claims[HC18].We might also disclose your personal data to our clients for roles where client will most likely be involved in the interview process.

Responding to any legal claims

Establishing, exercising or defending ASI’s legal position.

Assessing and monitoring equality, diversity and inclusion (where permitted by law)

Gender and ethnicity pay gap data used for reporting purposes; identifying and addressing disability support requirements; monitoring and reporting on diversity data and employment trends to ensure that our processes are fair.

Verifying that you are suitable for employment and/or have the right to work in the respective country/ies where the role will be based or to where you may need to travel

This will depend upon applicable local law and the role requirements, for example drivers’ licences and history checks for roles with access to company cars.

Automated Decision-Making

Automated decision-making is the process of making objective decisions by automated means, based on pre-defined criteria, without any human intervention. ASI does not make any decisions in relation to your application without human involvement.

Who we may need to share your personal information with

ASI will share your personal information with our trusted business partners (including suppliers and service providers) or other third parties only when it is necessary and proportionate to do so. We may share personal information with:

  • External service providers who help us communicate with you and deliver our programmes, products, information and services, process visa and work permit applications, support our technology systems and infrastructure or manage access to our work premises and facilities.

  • Regulatory authorities for visa and immigration purposes, tax audits or investigations.

  • Law enforcement agencies investigating alleged criminal offences by you, another individual or an organisation.

  • Clients and partners who are involved in the interview process, any recruitment agency who have progressed your application and referees to update the status of your application.

Please note that we will never sell your personal information to another organisation for any purpose.

Processing your personal information in (or from) other countries

We are a global organisation and our clients and trusted business partners (including service providers, advisors, subcontractors and suppliers) are have operations all over the world. This means your personal information may need to be accessed, stored, used, handled or otherwise processed in countries outside of the one where you are normally located, for the purposes described in this recruitment privacy notice.

We may transfer your personal information to other companies within ASI which are outside your country of residence (and which may have a different level of data protection to your home country such as ASI in India) for the purposes described in this Privacy Notice. In order to provide adequate protection of your personal information, we have in place data encryption, role-based access permissions and contractual arrangements (where appropriate) with our group companies which cover these transfers, and we will take all reasonable measures to safeguard your information whenever it is transferred including between different companies within our group of companies.

How we protect your personal information

We work hard to maintain and improve security measures that prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to personal information to individuals or organisations who have a legal right of access (for example, regulatory authorities or law enforcement agencies) or a legitimate business need to know, for example line managers, HR professionals and (subject to appropriate contractual terms and conditions) our clients, subcontractors and service providers or other third parties.

Our service providers and subcontractors will only process personal information under our instructions, and we ensure that all third parties (including clients) are subject to a legal duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any relevant regulator or supervisory authority of a breach when required.

Please also see our Information security policy for more information.

How long we keep your personal information

We will only keep your personal information for 1 year or for a period you have consented for. In certain cases, if required to do so by law (for example, tax, health and safety, immigration, financial audit, litigation or dispute), we may need to keep personal information for an extended period of time. Specific retention periods are defined, recorded and applied by the business unit responsible for the personal information to which they apply.

When your personal information is deleted or destroyed, we ensure that it is safely and permanently deleted or disposed of in accordance with any local legal requirements.

Your rights over your personal information

Depending on applicable law, you may have certain rights with respect to your personal information.

  • You may have the right to access, correct, update or request deletion of your personal

  • information;

  • You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information;

  • You may have the right not to have a decision made about you that is based solely on automated processing, including profiling if that decision produces legal effects about you

  • or significantly affects you. ASI does not, as part of its recruitment process, make solely automated decisions about candidates.

  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; and

  • You have the right to complain to a data protection authority about our collection and use of your personal information.

UK only: to exercise any of your rights relating to your personal information, please contact us through people@adamsmithinternational.com, or send an email to asi.dpo@adamsmithinternational.com.

We endeavour to respond to all valid requests within one month of receipt, or any alternative time period specified by law. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. To help us provide a response in a timely manner, please be as specific as possible when describing both the information you believe may exist and its possible sources.

You will not normally have to pay a fee to exercise any of these rights, and your application will not be affected in anyway. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

For all other countries: please speak with the People and Talent co-ordinator who has managed your recruitment.

In addition to the above, you may also have the right to contact a privacy and data protection regulator in the country, state or province where you are located if you are not happy with how we are processing your personal data.

Contact us

If you have any questions about this privacy notice please contact people@adamsmithinternational.com for further information.

If you have any specific concerns about this privacy notice, or how we have used your personal information, please contact asi.dpo@adamsmithinternational.com



Applicant Privacy Notice V1 2022