The Information we collect
Factual Limited (also referred to as "Factual ", "we" or "us") collect personal data about you when you register on our [Applicant Site] or apply for a role. The personal data you may provide includes:
- e-mail address and phone number
- CV, including work experience, qualifications, skills and education history
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
If you apply for a role and/or are invited to an interview, we may collect further information, such as:
- Factual application
- interview notes
- testing results
In addition, Factual automatically collect information about the website from which you came to our Applicant Site. Factual also collects information on the parts of the Applicant Site that you visit, the type of browser you use and the times you access the Site. However, this information is aggregated and is not used to identify you.
Purposes and legal bases
Factual may access, use and store your personal data for the reasons set out below:
- Where this is necessary for Factual to review and assess your application for employment including:
- assessing your skills and interest in career opportunities at Factual;
- processing your application,
- analysing your qualifications,
- verifying your identity and your eligibility for employment; and
- communicating with you about your application, to respond to your inquiries and schedule interviews.
- Where necessary for Factual's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including:
- protecting our legitimate business interests and legal rights, such as use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements; and
- maintaining the security and integrity of our facilities, equipment and electronic platforms, such as administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
- Where necessary to comply with a legal obligation.
- Disclosures to law enforcement agencies or in connection with legal claims, or regulatory purposes (including disclosure of such information in connection with legal process or litigation).
- Where you have given consent.
- For example, we may ask for your permission in circumstances where we conduct a criminal background check (for more on pre-screening checks see below).
To verify the information you provided to us, Factual may obtain information from third parties – such as educational institutions where you have studied, former employers and government agencies (where required to check your right to work for Factual). On some occasions, we will ask you for your consent to do this.
Who we share your information with
Factual employs the services of third parties to help us in certain areas, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies who assist in the recruitment process. For general recruitment services, Factual employs Greenhouse as its applicant tracking system. Factual generally does not conduct pre-employment screening, but Factual may conduct pre-employment screening in certain cases through Scherzer International or similar providers. Where Factual does carry out pre-employment screening you will be informed of this.
Factual will, at all times, control and be responsible for the use of your information. Your application may also be shared with different entities within Factual, e.g. Factual Inc. in the US, depending on the role for which you apply.
Your personal data may also be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the unlikely event that a Factual business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
We may use aggregated information so we can administer and improve the Site, analyse trends and gather broad demographic information. Factual may pass this information to third parties.
We may use a fully automated assessment process to determine your suitability for potential future assignments or roles. This process allows us to match your qualifications and experience against the requirements for the role and will be used to determine whether or not to shortlist you for the role. Should you wish to, you can ask us to reconsider decisions made by the fully automated process.
How we store your information and your rights
We retain all the information we gather about you until you ask us to change or remove your personal data, or otherwise for up to one year. Interview notes and testing outcomes of unsuccessful applicants are deleted after one year.
Factual takes measures to secure your personal data from accidental loss and from unauthorised access, use, alteration or disclosure. Data is transferred securely using SSL encryption and stored on secure servers. Additionally, we take further information security measures including access controls, stringent physical security and robust information collection, storage & processing practices. However, the internet is an open system and Factual cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal information for improper purposes.
Factual is a global group of companies with office in USA and EEA, and as a result, your information may be transferred outside the EEA to a country that may have different data protection laws. Factual will always take steps to ensure your information is adequately protected if transferred to these countries; for example, when transferred to Factual in the USA, such transfers are protected by the EU Commission approved standard contractual clauses.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
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).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our data protection officer ("DPO") – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Changes to this Privacy Notice
If our privacy notice changes in any way, Factual will place an updated version on this page and will notify you. Regularly reviewing this page ensures that you are always aware of what information we collect, how Factual uses it and under what circumstances, if any, we will share it with other parties.
If you have any questions about this privacy notice or your personal information, please contact us. We can be contacted by emailing email@example.com, or by post to Factual,90 New Fetter Lane, London, United Kingdom, EC4A 1JP. If you have any questions, you can contact your data protection officer by DPO@factual.com.
I certify that the information which I have provided is accurate and complete and by submitting my personal information I confirm I understand that it is being processed for the purposes described above. Where relevant to the selection criteria for any vacancy, I further agree to update my personal information should my eligibility for that vacancy change.