Candidate Privacy Policy

General Candidate Privacy Policy for Job Applicants at Chenavari Investment Managers

Chenavari Investment Managers cares about the protection of your personal data. This Candidate Privacy Policy (the “Policy”) explains how and for what purposes Chenavari uses your personal data. Certain contents of the Policy, including data subject rights, may apply only where our processing of your personal data falls within the scope of specific data protection laws (in particular, the United Kingdom’s Data Protection Act 2018 as thereafter amended and the General Data Protection Regulation, (“EU GDPR”). For the purposes of the Policy, “Data” shall mean personal data, i.e. any information relating to an identified or identifiable natural person. The terms “you” and “your” shall refer to you as a natural person,. “Chenavari”, “we”, “us” or “our” shall mean Chenavari Financial Group Ltd, Chenavari Asset Management SAS, Chenavari Investment Managers (Luxembourg) SARL and any of their affiliates.

The Data we collect and process

As part of submitting your CV and other data in relation to a job advertisement within the Careers page (“Application Process”), we collect and process your Data, which includes all the information you provide us in your resume, diploma, personal statement, job references, and any other documents you submit. During job interviews, we may also process any information you disclose to us. If required for certain positions, we may administer computer-based tests, and the results will be processed. With your consent, we may contact your references and process the information we receive from them.

The Data we typically collect and process during the Application Process includes, but is not limited to, your name, application photo (if any), residential and email addresses, phone number, date and place of birth, nationality, immigration status, marital status, academic background, professional training, work experience, previous employers, job titles, work hours, salary, bonus, criminal and debt records, career objectives, information on directorships, non-vocational activities, and external mandates such as lectureships. We may also process Data regarding your health status, if necessary. Finally, we will evaluate your eligibility for the position based on interviews, documentation, and results of tests, as well as any evaluations from third-party references.

The reasons and legal grounds for our utilization of your Data

We collect and process your Data to assess your qualifications for the job. If we hire you, we will also use your Data to prepare the employment contract. If you send us an unsolicited application, we may review your Data periodically to identify possible matches with job openings. Since we process your Data in response to your job application, we consider our activities to be at your request and aimed at the potential employment relationship.

We operate in a highly regulated, competitive, and complex industry. To maintain our position, we require highly skilled and motivated employees who share our values of integrity, honesty, and sustainability. Therefore, we have a legitimate interest in thoroughly evaluating all job applicants. In addition to reviewing your resume and conducting interviews, we may administer computer-based tests to assess your suitability more comprehensively. If we decide to use such tests, we will inform you beforehand and discuss the results with you later.

We will obtain your explicit consent where required, such as before contacting your job references or processing your health information, as required by applicable data protection laws.

To whom we transfer your Data

During the Application Process, we may share your Data with the HR department, the relevant line manager and other individuals of the team or department to which you applied. Your Data or parts of it may also be disclosed to colleagues you would be working with on a regular basis. Additionally, we may transfer your Data to third-party recipients, such as external service providers responsible for evaluating computer-based tests or conducting data checks. Your Data may also be shared within Chenavari, which operate in various countries, including the United Kingdom, Luxembourg, France, and Tunisia. In some cases, the recipients of your Data may be located outside the EEA, particularly in Tunisia. In such cases, we will take appropriate measures to ensure adequate data protection safeguards, such as implementing model contract clauses approved by the European Commission.

Data Retention

At Chenavari, we take the retention of personal information collected under our Policy seriously, ensuring that it is based on both our business needs and legal requirements. We hold onto personal information only for as long as necessary for the specific purpose(s) for which it was collected, as outlined in our Policy, as well as any other related purposes that are permissible. In the absence of specific instructions or applicable laws, we may retain the personal information provided by you for the purposes described in our Policy, including notifying you of potential job opportunities or other relevant updates via email. Any details of successful applicants will be transferred to their employment files, and we will provide them with information regarding retention periods at the time of their employment, if necessary.

Your rights

As someone whose Data we hold, you are entitled to exercise the following rights:

Right to access Personal Data

You have the right to seek a copy of the personal information we keep on you and the right to know what information we have about you:

the source of your Personal Data;
the purposes, legal basis, and methods of processing;
the data controller’s identity; and
the entities or categories of entities to whom your Personal Data may be transferred.

Right to rectify or erase Personal Data

You have the right to ask us to correct any incomplete or incorrect Personal Data. Before making corrections, we might try to confirm that the personal data is accurate.

You may also ask us to delete your personal information in certain situations:

it is no longer required for the purposes for which it was collected;
you have revoked your consent, if the processing of your data was based on your consent;
you have successfully exercised a right to object (see Right to object below);
it has been processed unlawfully;
it is required by law; or
it is necessary for us to comply with a legal obligation.

We are not required to comply with your request to delete Personal Data if the processing of your Personal Data is necessary for any of the reasons below:

for compliance with a legal obligation; or
for the establishment, exercise, or defence of legal claims.

Right to restrict the processing of your Personal Data

You can request that we limit how we use your personal data in the following circumstances:

to enable us to confirm its accuracy if its accuracy is disputed; or
despite the fact that the processing was illegal, you do not want it removed; or.
we still need it to make, use, or defend against legal claims even though we no longer need it for the reasons it was collected; or
Your right to object has been used, and the verification of any relevant overriding grounds is still pending.

We can continue to use your Personal Data following a request for restriction:

where we have your consent; or
to establish, exercise, or defend legal claims; or
to protect the rights of another natural or legal person.

Right to object to the processing of your Personal Data

If you believe that your fundamental rights and freedoms are more important than our legitimate interests, you can object to any processing of your personal data based on our legitimate interests.

If you object, we have the opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.

Right to object to how we use your Personal Data for direct marketing purposes

You can ask us to change the way we contact you for marketing purposes.

You can ask us not to transfer your personal data to unrelated third parties for direct marketing or other purposes.

Right to obtain a copy of Personal Data safeguards used for transfers outside your jurisdiction

You have the right to request a copy of or a reference to the safeguards that apply when your personal data is transferred outside of the European Union / United Kingdom.

To protect business terms, we might redact data transfer agreements.

Right to lodge a complaint with your local supervisory authority

In the UK Information Commissioner’s Office is the main regulatory body in charge of regulating Chenavari Investment Managers in terms of privacy and data protection. In case of complaint, you should contact the Information Commissioner’s Office (ICO) on its website ico.org.uk.

If you are unhappy with the way your personal data is being processed, you also have the right to complain to your local supervisory authority.

In France, you can make a complaint to CNIL on its website www.cnil.fr or by post to the following address: 3 Place de Fontenoy, TSA 80715, 74334 Paris Cedex 07.

In Luxembourg, you can make a complaint to CNPD on its website https://cnpd.public.lu/fr.html or by post to the following address: Commission nationale pour la protection des données, Service des reclamations. 15, Boulevard du Jazz, L-4370 Belvaux

While you are always free to get in touch with your supervisory authority, we ask that you please try to settle any disputes with us first.

Please send us a request at the address or email listed at the end of this policy below if you wish to exercise any of the rights mentioned above. Please specify in your message which right you wish to exercise and which information you wish to access, review, correct, or delete.

Before providing you with the Personal Data you’ve requested, we may need more proof of your identity for security reasons. In cases where it is legal, such as, when your request is obviously unreasonable or excessive, we reserve the right to charge a fee.

We will use every reasonable effort to promptly honor your request, subject to legal and other permissible considerations, or we will let you know if we need more details to complete your request.

It is possible that we won’t always be able to fully satisfy your request, for instance, if doing so would violate our obligation of confidentiality to others or if we have another legal option.

Important note

As part of your Application Process, it may be necessary for us to process personal data of individuals related to you, such as your references or former employers. If this is the case, it is important to notify those individuals and we kindly ask that you do so.

Getting in touch

With regard to our use of your Data, you may contact our Data Protection Officer at:

Email Address: dataprotectionofficer@chenavari.com

Candidate Privacy Policy