Standard Life Aberdeen is committed to protecting your personal information.
Who we are
How to contact us
FAO Data Protection Officer
Standard Life Aberdeen plc
1 George Street,
Information we collect and use
Information about you that we collect and use during the application and recruitment process with the Company includes:
- information about who you are e.g. your name, date of birth, address, contact details, gender, National Insurance number, passport and visa details
- information connected to your education e.g. qualifications and training records
- information about your previous employment history e.g. details of past employment (including start and end date, reasons for leaving, organisations you have worked for, roles held and references)
- information about your contact with us e.g. meetings, phone calls, emails / letters, interview comments and notes
- information collected when visiting any of our group offices e.g. visual images collected by closed circuit television (CCTV)
- information classified as 'sensitive' personal information e.g. relating to your health, immigration status, information to support diversity within our company
Where we collect and use sensitive personal information, this information will only be collected and used where it's needed to provide or perform the contract of employment or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.
Where we collect your information
We may collect your personal information directly from you, from a variety of sources, including for example:
- an application for employment within the company
- phone conversations with us
- emails or letters between us
- interviews with our people consultants and/or prospective manager(s)
We may also obtain personal information from third parties such as employment agencies, former employers and agencies we work with to conduct security and ID checks.
Why we collect and use your information
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:
- it's necessary to provide you with a contract of employment e.g. we will require some personal information including your name, address and date of birth
- it's necessary for us to meet our legal or regulatory obligations e.g. conducting the necessary checks to determine any criminal record / convictions which may impact fitness for propriety for employment
- it's in the legitimate interests of the Company e.g. for the following activities:
- recruitment and succession planning
- promoting diversity and inclusion in the workplace
Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be.
- you have given us your permission to use your information: for example, where you have not been successful for a particular role but we request to keep your information on our records so we can contact you about other potential opportunities that may arise.
Who we may share your information with and why
We may share your information with third parties for the reasons outlined above in 'Why we collect and use your information.'
We will share your information with:
- other parts of Standard Life Aberdeen plc. who support us in the provision of services to our potential employees
- credit reference agencies for the purposes of conducting a credit check and ID verification
- companies we have chosen to support us in the recruitment process e.g. recruitment agencies and companies who help us in our contact with you, for example an internet service provider
- our regulators, including the Financial Conduct Authority, Prudential Regulation Authority and the Information Commissioner's Office if required for the role you have applied for
- law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime
Where your information is processed
The Company is part of a global organisation and to ensure the provision of effective and efficient services and communication throughout our group, we are required to transfer your data internationally (such as to our group companies in Europe, Asia-Pacific and North America).
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice, providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information
If you are successful in your application and accept an offer of employment from us, we will continue to process your personal information in line with our obligations in relation to your contact of employment.
If you are unsuccessful in your application we shall retain your personal information for a period of 6 months from the date of advising that your application has been unsuccessful after which time it shall be erased.
You have a number of rights under data protection laws which may be exercised in certain circumstances.
Right to be informed about how and why we are processing your personal information
Right of access to personal information relating to you
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
Right to request recertification of inaccurate or incomplete personal information
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure or your personal information
You can ask for your information to be deleted or removed if there is not a compelling reason for Standard Life Aberdeen to continue to have it.
Right to restrict processing of your personal information
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information - but ensures that we don't use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
Right to object to processing of your personal information
You can object to Standard Life Aberdeen processing your personal information where it's based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we are using it for scientific / historical research and statistics.
Right to not be subject to automated decision making including profiling
You have the right to ask Standard Life Aberdeen to:
give you information about its processing of your personal information
request human intervention or challenge a decision where processing is done solely by automated processes
carry out regular checks to make sure that our automated decision making and profiling processes are working as they should
You can exercise these rights by contacting our Employee Lifecycle team at firstname.lastname@example.org
How to make a complaint
While we hope we can resolve any complaints for you, you do have the option to complain to the ICO (whether or not you have exhausted our complaints procedure). The ICO's contact details are:
Phone helpline (UK): 0303 123 1113
Phone helpline (outside UK): +44 1625 545 700
Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
The contact details for the Office of the Information Commissioner in Ireland are:
Phone: +353-1-369 5689
Postal address: Office of the Information Commissioner, 18 Lower Leeson Street, Dublin 2, DO2 HE97
If you are based elsewhere in the EU, you can find contact details for your local data protection authority on the Europa website: http://ec.europa.eu/
The contact details for the Office of the Privacy Commissioner for Personal Data in Hong Kong are:
Phone: +852 2827 2827
Address: Room 1303, 13/F, Sunlight Tower, 248 Queen's Road East, Wanchai, Hong Kong