The purpose of this document. Foster + Partners is committed to protecting the privacy and security of your Personal information. This Pre-hire Privacy Notice describes Foster + Partners’ privacy practices in relation to personal information collected from actual and potential job applicants (“you”) as part of our pre-hire recruitment processes. It makes you aware of how and why your personal information will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 (the “DPA”) and the General Data Protection Regulation (“GDPR”).

It is important that you read this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal information about you, so that you are aware of how and why we are using such information. This Notice does not form part of any contract of employment or other contract to provide services. We may update this Notice at any time.

Foster + Partners is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

Reference in this Privacy Notice to “Foster + Partners” means Foster + Partners Group Limited or any of its subsidiaries, so when we mention “Foster + Partners”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Foster + Partners group which you have had dealings with.

This Privacy Notice describes:

• what personal information we collect about you.
• how we obtain your personal information.
• how and on what basis we use your personal information.
• how we use analytics and cookies.
• how long we keep your personal information.
• who we share your personal information with.
• how we protect your personal information.
• your rights regarding your personal information.
• changes to this Privacy Notice.
• who to contract with questions or concerns.

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

In this Privacy Notice we use the words 'personal information' to describe information that is about you and which identifies you.

As part of our pre-hire application and recruitment process we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae, portfolio and covering letter.
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, marital status, nationality and current salary.
• Any information you provide to us during an interview.
  - Copies of Right to Work documentation.
• Information provided by your social media account where you sign in or register to apply for an actual or potential position using a social media account.
• Technical information, to the extent that it constitutes personal information, such as information from your visits to our website, activity on the website or applications (such as IP address and other online identifiers) or in relation to materials and communications we send to you electronically.
• Information you provide to us for the purposes of attending our premises, including access and dietary requirements, or generated by us in connection with your attendance, such as CCTV and access records.
• Any other information relating to you which you may provide to us or a third party on your behalf (such as a reference).

We may also collect, store and use the following types of more sensitive personal information which require a higher level of protection (see Sections 6 and 7 for further details):

• Information about your race or ethnicity, religious beliefs and sexual orientation.
• Information about any disabilities (under the Disability Act 2010) you consider you may have.
• A confirmation from PeopleCheck of whether you have any criminal convictions against you.

We may collect personal information about you from the following sources:

• Directly from you when you apply for a role or otherwise submit your personal information to Foster + Partners, for instance via its website.
• From third parties, such as recruitment agencies acting on your behalf or referees nominated by you.
• From partners and staff of Foster + Partners as a result of an internal recommendation or referral or generated in the course of our recruitment processes.
• From People Check, who will provide to us a summary confirming unspent criminal convictions, financial probity, identity, education, professional history and visa status if applicable.
• While monitoring our technology tools and services, including our websites and email communications sent to and from Foster + Partners.
• When you provide it to us, or interact with us directly, for instance engaging with our staff.
• Your named referees, from whom we collect references.

We will only use your Personal information when the law allows us to.

Most commonly, we will use your Personal information in the following circumstances:

• To take steps at your request in anticipation of entering into a contract.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests to run a successful international design practice, and your interests and fundamental rights do not override those interests.

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.

It is in our legitimate interests to assess potential employees and to recruit.

Having received your CV and covering letter or application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and carry out a criminal record check before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use anonymised information about race or national or ethnic origin, religious or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Prior to entering into an employment contract with you, a criminal check relating to unspent convictions (Basic DBS) will be conducted on our behalf, by a third party called People Check. We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history (in line with UK rehabilitation rules) which makes you unsuitable for the role. People Check will provide us with a summary confirming whether you have any criminal convictions against you.  Once the hiring process is complete, People Check will destroy the physical criminal certificate after a period of 6 months, and the digital copy will be deleted after a period of 1 year.

Automated decision making takes place when an electronic system uses Personal information to make a decision without human intervention. We do not currently make any decisions about you using automated means. We will update this Notice if this position changes.

For information on use of Cookies on our website please refer to our Cookies Policy.

We are an international design practice and may share your personal information with other entities in our group when processing your application.

We may share your personal information with the following third parties for the purposes of processing your application, where required by law or where we have another legitimate interest for the purpose of running a successful international design practice in doing so:

• Your recruitment agent, where you have engaged one, relating to the conduct and outcome of the application.
• IT and other service providers to Foster + Partners. For instance, the recruitment website is powered by our service provider Tandem Talent. Tandem servers will process personal information on behalf of Foster + Partners in the course of providing software and support for our recruitment system.
• PeopleCheck in order to carry out background checks as part of our hiring process of successful candidates.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of some of these measures can be found in our Privacy Policy, or may be obtained from the Data Protection Manager.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will you use my information for?

We will retain your personal information for as long as is necessary to process your application. For unsuccessful candidates, we will retain your personal information for a period of 6 months (unless otherwise agreed with you) after we have communicated to you our decision not to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Manager in writing.

When you apply for a role, you provide consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Data Protection Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal information securely.

We have appointed a Data Protection Manager to oversee compliance with this Privacy Notice:

Nadeem Mir
Data Protection Manager
dataprotection@fosterandpartners.com
T +44 20 7738 0455

If you have any questions about this Privacy Notice or how we handle your personal information, please contact the Data Protection Manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

We reserve the right to update this Privacy Notice at any time, and we will publish a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal information.