We are Titan Wealth Holdings Limited (“Titan Wealth”) and treating individuals and their personal information with respect reflects our core values as a business. Titan Wealth is committed to upholding the laws and guidance that protect you and your personal information, respecting your privacy and keeping your information safe. We also want you to be fully informed about what we do with your personal information and that is the purpose of this privacy notice.

You can find out full information about how and why we use your personal information by expanding each of the sections below.

 

Our role and when this privacy notice applies

In this privacy notice any reference to “us”, “we”, “our” or “ourselves” is a reference to the entity in the Titan Wealth Group (being Titan Wealth Holdings Limited and our subsidiaries) with whom you are applying for a role or another Titan Wealth Group entity which is processing your application. Any reference to “you”, “your” or “yourself” is a reference to you as someone who is a potential candidate for employment or a services contract with the relevant Titan Wealth Group company.

For the purposes of data protection laws and this privacy notice, we are the controller of your personal information, meaning that we are responsible for deciding how we hold and use your personal information. Titan Wealth’s registered office is at PO Box 264, Forum 4, Grenville Street, St Helier, Jersey, JE4 8TQ (company number: 132723), but our business address is at 101 Wigmore Street, London, W1U 1QU.

This privacy notice provides details in accordance with data protection laws about how we collect and use personal information about you during and after your engagement in any recruitment process with us.

If you submit an application through Titan Wealth’s website recruitment portal, Lever, as operator of the website, will pass the application to the appropriate Titan Wealth Group employer entity for the role you have applied for. That Titan Wealth Group entity will be the controller of your information, as potential employer entity, and will be responsible for the selection and recruitment process.

If you have any queries regarding your personal information you can email [email protected].

 

Data protection principles

We are committed to being transparent about how we collect and use your personal information and in meeting our data protection obligations. Data protection laws say that the personal information we hold about you must 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.

To make sure this happens we are required under data protection laws to notify you of the information contained in this privacy notice. It is important that you read this document before you begin interacting with us or deal with us in any way so that you understand how and why we will process your personal information.

 

What personal information do we collect?

For recruitment and selection purposes we collect the following information:

·       Personal details including full name, title, date of birth, addresses, telephone numbers, email address, national insurance number, social security number, copy of passport and ID cards, and tax details.

·       Information to assist us monitor diversity (optional).

·       Information from your CV or gained from the sources mentioned below, about your employment history, education, skills, experience, and qualifications.

·       Interview feedback, results of aptitude tests and assessments of your suitability for the role, where applicable.

·       Information obtained through your communication and correspondence with us (including but not limited to the content, date and time of your email correspondence).

For referencing and pre-employment screening purposes we collect the following information:

·       References from past employers (including regulatory references if required for your role).

·       Immigration status, nationality and citizenship and copies of right to work documentation.

·       Credit, criminal, identity, financial, fraud and sanctions checks, which include past criminal record, credit history and sanctions status.

·       Academic qualifications checks.

 

Where do we collect your personal information from?

Much of your personal information we receive directly from you. This includes correspondence with you, interviews, meetings or other interactions with us or other personal information you provide to us. We also receive some personal information from recruitment consultants, our business partners who provide us with candidate information, professional and social media networking sites that you subscribe to, such as Linkedin, your past employers where you have nominated them as referees; existing Titan Wealth employees who refer or nominate you for roles with us, credit checking agencies; fraud and sanctions checking agencies; background and criminal records checking agencies; educational establishments from whom you have gained qualifications; and any specialist firms we use to advise us on matters such as visa, immigration or tax requirements for specific situations.

 

 

How will we use your personal information?

There are various ways we may need to use your personal information in the context of your relationship with us or our use of your personal information. We will only use your personal information when the law allows us to. This means we must have one or more legal bases to use your personal information.

We have set out the main uses below, and indicated the main applicable legal bases of processing, but there may be other specific uses which are linked to or covered by the uses below.

Use of data	Legal basis
Assess suitability for roles and opportunities that we have available (including, in some cases, verifying your qualifications and references with those third parties you name).	·       Pursuing our legitimate interests ·       Compliance with legal obligations ·       Necessity to enter into or perform a contract you are a party to ·       We may also rely on your consent in some limited cases
Meet our legal and regulatory obligations.	·       Pursuing our legitimate interests ·       Compliance with legal obligations
Maintain consistent practices and procedures with respect to the collection, use, disclosure, transfer and processing of personal information across all Titan Wealth Group companies worldwide. These practices and procedures include the effective recording, management and administration of personal information.	·       Pursuing our legitimate interests ·       Compliance with legal obligations
Maintain consistent practices and procedures with respect to the recruitment of personnel across the Titan Wealth Group, including the performance of human resources and other functions of the Titan Wealth Group.	·       Pursuing our legitimate interests
Maintain contact with you in the future and notify you of relevant job vacancies with a member of the Titan Wealth Group that you might be interested in. Please note that if you do not want us to retain your information, or want us to update it at any stage, please contact us in accordance with the “Contacting us” section.	·       Pursuing our legitimate interests ·       We may also rely on your consent in some limited cases

Please note that  if your application is successful and you are subsequently offered and accept employment at Titan Wealth, the information we collect during the application and recruitment process will become part of your employment record.

 

Sensitive personal information

The Titan Wealth Group is firmly committed to fostering an inclusive and equitable environment for everyone who works with us, regardless of their race, age, gender, sexual orientation, religion, physical ability or disability, or political affiliation. We believe that having a diverse team allows us to create the best possible outcomes for our clients and team members. We strive to provide equal opportunities in all aspects of the workplace with respect to recruitment and career advancement, pay and benefits, training and development opportunities and other job-related activities.

In addition, we want to ensure accessibility needs are well supported, if you require specific support, please advise us.

In order to pursue these objectives, we collect certain personal information from recruitment candidates, on a voluntary basis, for the purpose of monitoring and promoting diversity and inclusion within our business. Individuals may choose to provide information such as their socio-economic background, military service, gender identity, ethnicity, disabilities, and/or sexual orientation. There are no consequences for the individual of choosing not to provide us with any diversity data.

We use this data to understand the diversity of our organisation and promote fairness and equality; to benchmark our progress; and to demonstrate to internal and external stakeholders that we are a diverse organisation with an inclusive culture. Diversity data is only used at an aggregate level which does not identify individuals. Your individual data is held securely on our HR system and is not shared with any third party, except the system provider for service and support purposes.

Where we are processing any sensitive “special category” personal information about you (which covers personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation) then we also need to have one or more of the following conditions for using your personal information. These include:

·       Where we have your explicit consent to do so.

·       Where it is necessary for us to comply with our obligations and exercise our rights in the field of employment law, social security law and social protection law.

·       Where we need to protect your vital interests (or someone else’s vital interests).

·       Where you have already made the personal information public.

·       In establishing, exercising or defending legal claims, whether those claims are by us or against us.

·       Where it is necessary in the public interest.

In some cases more than one legal bases may apply to our use of your personal information.

Where we process criminal records information about you, then we will either do so either to comply with legal obligations or with your consent.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you by updating this privacy notice on our website, so please check back regularly for any updates.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. We will rarely need to rely on your consent to process any of your personal information.

 

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision about that person without any human intervention which produces legal effects concerning them or similarly significantly affects them. We do not currently use this type of automated decision making in our business in relation to you.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making unless we have a lawful basis for doing so and we have notified you.

 

Who do we share your personal information with?

When using your personal information we may share it with third parties but we will only do so when it is appropriate and we have a legal basis for doing so.

We may disclose your personal information to other members of the Titan Wealth Group, in compliance with local law, for the purposes of:

·       the management and administration of the Titan Wealth Group business, including the maintenance of the centralised databases storing personal information;

·       enabling the performance of the functions that each of the Titan Wealth Group businesses may perform relating to regional or global HR decisions within the Titan Wealth Group; or

·       assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across the Titan Wealth Group.

In addition to the above, Titan Wealth (and the other Titan Wealth Group companies to whom your personal information is disclosed) may share your personal information outside the Titan Wealth Group:

·       to third party agents or contractors for the purposes of providing services to us (e.g. the providers of our electronic data storage services, outsourced HR service providers, IT and communications providers, law firms, accountants and auditors, research providers, payroll providers, health insurance and retirement providers). These third parties will be subject to confidentiality requirements and they will only use your personal information as described in this privacy notice;

• if we are acquired by a third party, in which case personal information held by us about you will be disclosed to the third party buyer;

·       to credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty or investment due diligence; and

·       to the extent required by law, for example if we are under a duty to disclose your personal information in order to comply with any legal obligation, establish, exercise or defend our legal rights.

 

International transfers

It may be necessary to share your personal information outside of the UK and the European Economic Area (the “EEA”). We may typically do this when service providers to our business are located outside the UK or EEA. These transfers are subject to special rules under data protection laws and additional protections will be applied. For example, the jurisdiction outside of the UK or EEA to which personal information is transferred may be approved by the UK Government, the European Commission or another data regulator, or the recipient may have agreed to standard contractual clauses approved by the UK Government, European Commission or a data regulator that oblige them to protect the personal information.

In all circumstances, we will ensure that the transfer is compliant with data protection laws and all personal information will be secure.

Our directors and other key staff working for us may in limited circumstances access personal information from outside of the UK and EEA if they are on holiday abroad outside of the UK or EEA. If they do so they will be using our security measures and the same legal protections will apply that would apply to accessing personal information from our premises in the UK.

In limited circumstances the people to whom we may disclose personal information may be located outside of the UK and EEA and we will not have an existing relationship with them. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

Your personal information may also be processed outside the UK or EEA when we use suppliers who have global operations as part of our recruitment process. Some of the suppliers we use to provide candidate information, skills assessments, testing, and HR systems, are based outside the UK and/or EEA.

If you would like any more details about how we protect your personal information in relation to international transfers, including a copy of any standard data protection clauses entered into with recipients of your personal information, then please email [email protected].

 

For how long do we keep your personal information?

Our retention period for candidate personal information, for recruitment purposes, is 2 years.

Your rights

As an individual whose personal information we collect and process, you have a number of rights. You may:

·       Withdraw any consent you have given to us, which is an absolute right (although this will only be relevant where we are relying on your consent as a basis to use your personal information). Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes for which you originally gave your consent, but withdrawing consent will not affect use that has already happened.

·       Request details about how your personal information is being used. This right is linked with the right of access mentioned below.

·       Request access and obtain details of your personal information that we hold (this is commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

·       Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

·       Request erasure of your personal information. This means that you can ask us to delete or stop processing your personal information, for example where we no longer have a reason to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (set out below). The right to have data erased does not apply in all circumstances.

·       Object to the processing of your personal information where we are relying on a legitimate interest (ours or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

·       Object to direct marketing where we are processing your personal information for direct marketing purposes. This is an absolute right.

·       Request the restriction of processing of your personal information. This enables you to ask us to stop processing your personal information for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing your personal information.

·       Request the transfer of your personal information to another party in certain circumstances.

·       Object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your personal information to another service provider or the right to object to automated decision making, may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal information which has legal or other significant effects for you. However, some of your rights have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

If you would like to exercise any of these rights, please contact us at [email protected].

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person or dealt with by a person who has no right to do so.

 

What if you do not provide personal information?

Generally, you are not obliged to provide us with any of your personal information. However, please note that in some cases failing to provide certain information may mean that we are unable to progress with your application or respond to your requests for information.

 

Contacting us

We are not required to appoint a data protection officer to oversee our compliance with data protection laws. If you have any queries regarding our use of your personal information or this privacy notice then please contact us at [email protected] or write to us at our business address at 101 Wigmore Street, London, W1U 1QU.

 

Complaints

We hope you don’t have any reason to complain, and we will always try to resolve any issues you have, but you have a right to lodge a complaint with a data protection supervisory authority, in particular in the country where you are habitually resident, where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).