Recruitment Privacy Notice for Marex entities in the UK and EEA

Introduction

In processing your personal data, the Marex Group is the Controller of your data. Please note that your personal data will be shared within the Marex Group for business administration purposes to the extent that is required. You can find the contact details of the Group Companies through the following link: https://www.marex.com/contact-us

1. Scope of Privacy Notice

What do we mean by “Personal Data” and “Processing”

This notice explains the categories of personal data we process of individuals who are applying to work for us, the purposes of processing the data and how that may affect you. We have a separate Employee Privacy Notice that applies to our current and former employees. It will be provided to you if you receive and accept an offer from us.

This notice explains:

what personal data we hold and why we process it;
the legal grounds which allow us to process your personal data;
where the data comes from, who gets to see it and how long we keep it;
the rights you have in regards to the personal data we process and how to exercise the same; and
how to contact us.

2. What do we mean by “Personal Data” and “Processing”

“Personal data” is information relating to you or from which you may be identified. It includes not only facts about you, but also intentions and opinions about you.

“Processing” means any operation which is performed on personal data. It includes the whole lifecycle of using the data from collecting it, holding it, disclosing it to deleting it, whether this is done manually or by automated means.

References in this notice to employment, work (and similar expressions) include any arrangement we may have under which an individual applies to provide us with work or services. By way of example, when we mention an “employment application”, that includes an application to become engaged as a freelancer. We use the word “you” to refer to anyone within the scope of the notice.

3. What are the grounds for processing?

Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. We have summarised these grounds as Contract, Legal Obligation, Legitimate Interests, Consent and Vital and Public Interest and outline what those terms mean in the following table. Where processing is based on a legal or contractual requirement or is necessary to enter a contract providing the data is required for us to be able to fulfil our obligations and exercise our rights. Failing to provide the requested information, may result into us not being able to proceed with the recruitment process.

Term	Ground for processing	Explanation
Contract	Processing necessary for performance of a contract with you or to take steps at your request to enter a contract.	This covers preparation of a contract, carrying out our contractual duties and exercising our contractual rights and obligations.
Legal Obligation	Processing necessary to comply with our legal obligations.	Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Legitimate Interests	Processing necessary for our or a third party’s legitimate interests.	We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your personal data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
Consent	You have given specific consent to processing of your data.	In general processing of your data in connection with employment is not conditional on your consent. However, there may be occasions where we do specific things such as request a reference and rely on your consent to our doing so.
Vital Interest	The processing is necessary in order to protect your or another person’s vital interests.	This refers to emergency situations, where we cannot acquire consent or use another legal basis and are required to use your data. It is extremely rare for this basis to be used.
Public Interest	Processing is necessary for reasons of substantial public interest.	This legal ground refers to any situation affecting the rights, health, or finances of the public at large.

4. Processing special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to stricter controls and security measures and considered by EU privacy law to be “special category personal data”.

If we process special personal data about you, we will make sure that one or more of the additional legal grounds for processing special personal data applies. To outline, these include:

Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law;
Processing being necessary for the purpose of establishing, making or defending legal claims; and
Processing for equality and diversity purposes to the extent permitted by law.

5. Further information on the data we process and our purposes

The data, the purposes and the grounds on which we process the same are detailed in the table below. The examples in the table are not exhaustive but encompass the core activities we perform in the course of recruitment.

Purpose	Examples of personal data that may be processed	Grounds for processing*
Recruitment	Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality, right to work, contact details, professional experience and education, including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information) language skills, and any other personal data that you present us with as part of your application related to the fulfilment of the role. We will also collect and process information concerning your application and our assessment of it including any background checks we may make to verify information provided and any information connected with your right to work. This may include as necessary for your role (and subject to legislation in your jurisdiction) checks verifying your job history, qualifications and previous renumeration as well as credit, criminal record, social media and adverse media checks. If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements. Should you be unsuccessful at this time, with your consent, we retain your CV for 24 months to consider you for other opportunities at Marex.	Contract Legal Obligation Legitimate Interest Consent
Administering our recruitment process	Evaluating your experience and qualifications against the requirements of the position you are applying for. · Administering our online careers portal. · Information such as your proposed salary and (if applicable) envisaged bonus levels. · Communicating with you in respect of any offer of employment we choose to make and providing you with information about our onboarding process.	Contract Legal Obligation Legitimate Interest
Entering into a contract with you (if you are made an offer by us)	Information on your terms of employment from time to time including your hours and working patterns, your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes.	Contract Legal Obligation
Contacting you or others on your behalf	Your address and phone number, emergency contact information and information on your next of kin.	Contract: Legitimate Interest
Payroll administration	Information on your bank account, financial data such as salary, bonuses, pension contributions and on tax and national insurance Your national insurance number or other government issued identifier.	Contract Legal Obligation
Physical and system security	CCTV images upon attendance for interview at our premises, system security measures such as log information.	Legal Obligation Legitimate Interest
Providing information to third parties in connection with transactions that we contemplate or carry out	Information on any offer made to you and your proposed contract and other employment data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer.	Legitimate Interest Legal Obligation
Monitoring of diversity and equal opportunities	Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will be aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymized diversity statistics with regulators if formally required / requested.	Legal Obligation
Meeting our duty of care and health and safety responsibilities in relation to Covid-19	We have a duty of care to ensure a safe place of work, as well as a duty of care to staff. For this reason, where reasonable and necessary, we may do the following in relation to Covid-19: · request information about whether you have had symptoms of the virus, close contract with confirmed cases or travelled to high-risk areas, whether you would be considered clinically vulnerable or clinically extremely vulnerable and whether you have been vaccinated. · conduct temperature checks before allowing entrance to our premises. · ask you to be PCR or Antibody tested before allowing entrance to our premises.	Legal Obligation Legitimate Interest
Disputes and legal proceedings	Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.	Legitimate Interest Legal Obligation Contract

* For further explanation on the grounds of processing applicable to each purpose, please see the table in section 3

6. Where the data comes from?

When you apply to work for us the initial data about you that we process is likely to come from you: for example, contact details, bank details and information on your immigration status and whether you can lawfully work in the country you applied to. Where necessary and in accordance with this Privacy Notice, we will require references and information to carry out background checks, in which case the data is obtained from the relevant third parties. We may also receive data from third party recruiters, agents and similar organisations as a part of the recruitment process. For further explanation of the grounds of processing applicable to each purpose, please see the table in section 3.

7. Who gets to see your data?

Where necessary and as set out this Privacy Notice, your personal data will be disclosed to relevant managers, HR and administrators for the purposes of proceeding with your application as described in this Notice. We will also disclose this to other members of the Group where necessary for decision making regarding your application – this will depend on the role you are applying for.

We will only disclose your personal data outside the Group if the disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you. We will disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party. However, we will only do this if these interests are not over-ridden by your interests and rights to privacy. Where

necessary, we will also disclose your personal data if you consent to it, where we are required to do so by law and in connection with criminal or regulatory investigations.

Examples of the circumstances in which your personal data may be disclosed include:

Disclosure to organisations that process data on our behalf such as our payroll service, insurers and other benefit providers, our bank and organisations that host our IT systems and data. This would normally occur if you accept an offer from us and would be carried out as part of the on-boarding process;
To third party recruitment consultants and similar businesses (including online recruitment portals) as a part of the recruitment process; and
Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request (see above).

8. Transfers outside of the UK/EEA – more information

In connection with our business and for employment, administrative, management and legal purposes, we will where necessary and as set out in this Privacy Notice transfer your personal data outside the UK and/or the EEA to members of our group and data processors and controllers in relevant jurisdictions.

9. Retaining your personal data – more information

The specific period for which we will keep your personal data depends on the applicable laws of the country your employment is governed by. However, we will not keep your data for longer than is necessary for our legitimate processing purposes. Should you be unsuccessful at this time, where you have consented, we will keep your CV and details for 24 months following the position being applied for having been filled.

For determining how long to keep your data, we will consider its relevance to our business and your potential employment in the future. We may also retain your personal data for the purposes of a possible legal claim, or other grounds specified in this notice.

If you would like your CV to be removed from our records for the purpose of being considered for future roles, you can contact our HR by e-mailing: Recruitment@marex.com.

10. Your Rights

The GDPR and the applicable national laws provide you the certain rights in relation to the personal data we process of you.

Please note, that exercising your rights is limited to the extent we are legally required to, or capable of, to fulfil your request. This means, that even if you make a request, we may not be able to comply with it partially or fully. This is due to country specific limitations to the rights, or another legally compliant reason, such as for example our legal obligation to continue processing the personal data for compliance purposes. Where we do not comply with your request, we will inform you of the reasons for not doing so.

Under the GDPR, you have the right to:

Access the personal data we process of you by requesting a copy;
Have your personal data rectified;
Have your personal data erased;
Object to the processing of your personal data;
Have your personal data processing restricted;
Withdraw your consent to process your personal data for a purpose you previously consented to. Withdrawing consent does not affect the lawfulness of processing, which was done before consent was revoked;
Receive a limited set of data transferred directly to another controller or processor, or directly to yourself; and
You also have the right to object to being subjected to profiling and automated decision-making and require a human review of any automated decision. We do not however process personal data in a manner, which would make this right applicable.

To exercise your rights, you can contact our Group Data Protection Officer (DPO) and the Privacy Team by emailing: dataprotectionoffice@marex.com.

11. Complaints

If you have complaints relating to recruitment process or want us to remove your CV from our database, you should raise these with HR in the first instance. You can contact them by emailing: Recruitment@marex.com.

If you have complaints, comments or questions relating to our processing of your personal data, you should raise these with the Group Data Protection Officer and / or the Privacy Team and by emailing: dataprotectionoffice@marex.com.

You also have the right to lodge a complaint with the local Data Protection Authority if you think that the processing of your personal data violates any provision of the GDPR.

12. Status of this notice

This notice can be amended at any time, by publishing the new version. This Privacy Notice does not form part of any contract of employment that you may enter into with us and does not create contractual rights or obligations.