Privacy Policy for Assessments

INFORMATION FOR DATA SUBJECTS

INTRODUCTION

Finance Foundry Ltd is a specialist assessment consultancy.  We supply assessment tools and services to customers around the world to assist with their recruitment, development and assessment programmes to find and develop the right people for their businesses.  

As part of our services, we act as the data Processors of Personal Data on behalf of our customers, who are the Data Controllers.  Finance Foundry Ltd Processes Personal Data in accordance with the written instructions of the Data Controllers.  You are the Data Subject and this policy sets out important information as to who will have access to your Personal Data, what it may be used for and your rights.

1.    IDENTITY OF DATA CONTROLLER AND DATA PROTECTION OFFICER

The identity and contact details of the Data Controller of your Personal Data are set out in the Schedule below, together with the contact details of the Data Controller’s Data Protection Officer, if any.  This is important if you need to obtain more information about your Personal Data or to exercise your rights as a Data Subject.  We recommend that you note these details in case of future need.  Finance Foundry Ltd will support the Data Controller in responding to such requests.

2.    PURPOSES OF PROCESSING

2.1    The Data Controller Group may use your Personal Data for its own human resources purposes.  Human resources purposes may include use as part of its pre-contractual processing prior to appointment or assessment of existing employees for promotion or development.

2.2    If a member of the Data Controller Group is carrying out assessments as part of services to its own customers, it may disclose your Personal Data to a customer on paper, email or other medium. A customer of the Data Controller Group may use the information for human resources purposes only.

2.3    If acting on the instructions of the Data Controller, Finance Foundry Ltd may use your Personal Data for human resources purposes and to provide human resources services to the Data Controller Group.

2.4    Finance Foundry Ltd may use your Personal Data to assist the Data Controller Group in the use and understanding of any Finance Foundry Ltd assessment tool and, if necessary, in IT system fault finding.

2.5    Finance Foundry Ltd online assessments may be used for Profiling in order to assess your suitability for a role.  

3    RIGHT TO OBJECT TO PROCESSING

You have a right to object at any time to the Processing of your Personal Data (including Profiling) but this will mean that you will be unable to participate further in the online assessment and may be unable to participate in a selection or development programme operated by the Data Controller.  Please see also paragraph 9 below (Data Subject Rights).

4    RESEARCH

4.1    To develop and maintain robust talent assessment solutions, Finance Foundry Ltd needs to use participant details to research and validate the models and theories on which we build our offering, ensuring that the data underpinning our tools is up to date. This helps ensure that employers’ decisions are based on fair, objective and scientifically derived information.  Finance Foundry Ltd is authorised by the Data Controller to use your Personal Data for monitoring, validation, statistical research, benchmarking, Product development and management purposes (“Research”). 

5    LEGAL BASIS FOR PROCESSING

5.1    The legal basis for Processing of your Personal Data is that it is necessary for the legitimate interests pursued by the Data Controller.  If EU Law applies, you have the right to object at any time to the Processing of Personal Data as described in this paragraph and the Data Controller should cease the Processing unless there are compelling legitimate interest reasons for continuing.

5.2    Customers of Finance Foundry Ltd operate in some territories where the applicable law requires a Data Subject to give consent to the Processing of Personal Data.  If you are asked to give such consent, paragraph 5.1 shall not apply and the lawful Processing of your Personal Data as part of a Finance Foundry Ltd assessment will be based on consent.

6    CATEGORIES OF DATA

On behalf of the Data Controller, Finance Foundry Ltd may Process: your e-mail address and other data necessary for us to identify you and generate a report as well as your responses to questions in online questionnaires and tests.  

Participation is voluntary but if you do not respond to a questionnaire or test that you are asked to complete, and where this questionnaire and/or test is part of a hiring process, your opportunities may be negatively impacted. Participation is voluntary but failure to provide data may impact on your overall assessment result.

7    RECIPIENTS OF DATA

The Data Controller Group.

The data processor, which will be the member of the Finance Foundry Ltd Group that has contracted with the Data Controller.

Finance Foundry Ltd Limited, which manages the data centres where Personal Data is Processed automatically, and acts as the sub-processor for other members of the Finance Foundry Ltd Group.

Other members of the Finance Foundry Ltd Group acting as sub-processors where required due to the nature and territorial scope of the contract with the Data Controller Group.

Finance Foundry Ltd’ agents, associates, integration partners, suppliers and other trusted third parties may be involved in the Processing of your Personal Data, where required due to the nature and territorial scope of the contract with the Data Controller Group.

Integration partners, suppliers and other trusted third parties may be involved in the Processing of Data Subject's Personal Data, on behalf of the Data Controller Group where required due to the nature and territorial scope of their business.

8    PROCESSING AND TRANSFERS TO THIRD COUNTRIES

8.1    Finance Foundry Ltd assesses Data Subjects on a worldwide basis.  Irrespective of location, all Processing of Personal Data by Finance Foundry Ltd is carried out in accordance with current EU data protection standards to ensure the security of Processing.

8.2    Where necessary, Personal Data may be exported outside the EEA, subject to adequate measures being in place for the security of the data. 

8.3    Your Personal Data may be collected on your first assessment by means of Finance Foundry Ltd tools or assessment services and on subsequent assessments

9    RETENTION CRITERIA

Personal Data should only be retained for as long as it is required for the Purposes.  Please contact the Data Controller for further details as to their policies and procedures. 

10    DATA SUBJECT RIGHTS

You, as a Data Subject have the following rights.

Where EU Law applies:

to request from the Data Controller access, rectification, erasure, restriction of Processing or to object to Processing, and to lodge a complaint with a Supervisory Authority.

Where Non-EU Laws apply:

your rights will be in accordance with such laws.

If you wish to exercise your Data Subject Rights, you should contact the Data Controller. Contact details are set out in the Schedule.

11    CONFIDENTIALITY

The Finance Foundry Ltd assessment tools and services contain valuable intellectual property rights and are disclosed to you on a strictly confidential basis.  They may not be copied, published or disclosed to any person or organisation without the prior written agreement of a director of Finance Foundry Ltd

DEFINITIONS:

Data Controller: the person, company or organisation set out in the Schedule.

Data Subject(s): all persons who provide Personal Data as part of the assessment process. This includes the Subject of the Assessment and, in the case of a 360 assessment, includes reviewers, for example the line manager, peers and/or reports of the Subject of the 

Assessment, whose input is combined into the assessment report.

Data Subject Rights: the rights described in paragraph 10 above.

EEA: the European Economic Area, being the European Union or the European Free Trade Area but excluding Switzerland.

EU Law: (i) European Directive 95/46/EC and (ii) from 25 May 2018, the General Data Protection Regulation (EU 2016/679) and any national implementing laws.  The General 

Data Protection Regulation applies to the Processing of Personal Data by a Controller or Processor within the European Union and/or where the Processing relates to offering goods or services to Data Subjects in the European Union and/or monitoring the behaviour of Data Subjects within the European Union.

Personal Data: data which relates to an individual who can be identified from such data, or from such data and other information which is in the possession of, or is likely to come into the possession of, the Data Controller. Personal Data refers both to data Processed on a computer and to certain kinds of manually Processed data

Processing: any operation or set of operations which is performed on Personal Data or sets of Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction. Process and Processed shall be construed accordingly.

Profiling: an automated Process that generates a profile which indicates aspects of likely job performance and behaviour.

Purposes: as referred to in paragraph 2 above.

Subject of the Assessment: the person undergoing assessment.                                                            

Data Controller Contact Details     

Data Protection Officer Guy.Hutchinson@thefinancefoundry.com

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