Recruitment
Privacy Notice

Introduction

Careers with Fundamental

Thank you for your interest in a career with Fundamental Group, including Fundamental Media Limited and its subsidiaries with operations in the United Kingdom, United States, Hong Kong and Australia. This Notice applies to personal information of individuals applying for employment, internships, recruitment or exploratory events and potential applicants for employment and sets out how and why we use personal data during the application process, 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. When we say “Fundamental“, “we” or “us” in this Notice, we mean the entity that you are applying to work for and/or that is engaging with you. For further details about how we use personal data more widely, please see our Privacy Policy.

Our Processing

Fundamental is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. We use the personal data you submit as part of your application for our recruitment purposes, specifically to review your application or CV. We may also collect additional personal data from you as the recruitment process progresses, including personal data which may be derived from an interview, test or presentation, for example. We may also process personal data about you where we undertake pre-employment screening and/or collect references or gather information from recruiters, websites or other publicly available sources to support or verify your application. In summary, our recruitment process may require that we process, store, and use some or all of the following categories of personal information about you:

  • Personal details such as name, address, telephone number, personal email address, date and place of birth;
  • Work history/job data; previous employers, positions, dates, etc.;
  • Compensation; basic salary, benefits, bonuses, etc.;
  • Education and work history including professional qualifications and skills;
  • Employer feedback/references to include regulated references where necessary;
  • Nationality/visa/right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
  • Photographs and images from recorded assessments or from onsite CCTV;
  • Results of Pre-employment screening checks (e.g. credit history, criminal records check where applicable as permitted under local law);
  • Assessment results e.g. Psychometric assessment results, results from gamification and video or telephone assessment.

We may collect this information in a variety of ways. As referred to above, your personal data is likely to be contained within application forms, CVs, covering letters or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Please note that you are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may be unable to process your application properly or at all. For example, if we require a credit check or references for the role you are applying for and you fail to provide us with relevant details, we will not be able to take your application further.

We may collect and share your personal data from and with third parties, such as referees, employment background check providers and criminal records checks (where applicable). We will seek information from such third parties only once a job offer has been made to you and it is our standard policy to obtain references for all successful candidates. Human Resources is responsible for securing explicit consent from candidates to contact referees and will ensure two references are obtained, with preference for one from a current or most recent employer and the other from a prior employer. Where this is not feasible, alternative references (e.g., educational or personal references) may be accepted.

Your personal data will be stored in our systems on servers in the UK, including on your application record, as part of HR systems and on other IT systems (including email).

We only process your information as is necessary for the purposes of progressing your application or as required by law or regulatory requirements and where we have a legal ground to do so, including:

  • Taking steps to administer and evaluate your application at your request prior to a potential offer of employment, which involves the processing of identification data, individual information, contact details, education and professional information, information obtained during your interview and information contained in your application form/CV.
  • Processing your personal data to ensure we are complying with our legal obligations. For example, verifying your identity and checking your eligibility to work in the UK before employment starts. We may also collect some sensitive personal data (e.g. disability information) in order to make reasonable adjustments to enable our candidates to apply for jobs and to ensure that we comply with regulatory obligations placed on us with regard to our hiring.
  • Processing where we have a legitimate interest in doing so, specifically in allowing us to manage and administer the recruitment process, assess and confirm your suitability for employment and decide to whom to offer a job. We may also need to process personal data from job applicants to respond to and defend against legal claims.
  • Processing, where applicable, other special categories of data, such as information about ethnic or racial origin, disability or sexual orientation, health or religion or philosophical belief, for equal opportunities monitoring purposes.
  • Processing, where applicable, information about criminal convictions and offences where relevant to the position in question.

We do not make any recruitment processes or decisions based solely on any automated (non-human) decision-making.

As referred to above we may share your personal data for the purposes of processing your application with suppliers who undertake pre-employment screening (including credit checking agencies and criminal record checking bureaus), academic institutions in validating relevant academic qualifications and suppliers who provide candidate interviews and/or assessment services to us (where applicable). Where a supplier processes your personal data on our behalf we contractually require that they process that data in full compliance with the law and solely in accordance with our instructions. We do not allow our suppliers to use your personal data for their own purposes.

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 instruction and they are subject to a duty of confidentiality.

If your application for employment is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process. 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 your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your personal data will be held will be provided to you in our Employee Privacy Notice, available to all employees.

International Data Transfers

Your personal information may be transferred to and processed by Fundamental or third parties located outside the country in which you are based and/or to and in other countries that may have different levels of privacy protection than your country. For example, this may occur when hiring managers are located overseas or when following up on references if a prospective employee has worked abroad previously. If you are located in the European Economic Area, Switzerland or the UK, this includes transfers to countries of which the relevant data protection authorities have not issued an adequacy decision. To ensure that your personal information receives an adequate level of protection, we implement intra-group data protection policies and adhere to intra-group data protection security procedures. These measures in addition include entering into legally binding agreements such as standard contractual clauses as well as conducting risk assessments to ensure that personal information is treated in a way consistent with applicable data protection laws.

Rights of access, rectification, erasure, objection, restriction and data portability

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

  • Request access to your personal information (commonly known as making 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 rectification 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.
  • 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.

Implementation, monitoring, and review of this Notice

The Group Counsel and Privacy Manager, together with the HR Manager and Directors has overall responsibility for implementing and monitoring this Notice. This Notice will be reviewed on a regular basis and additionally whenever there are relevant changes in legislation or to our working practices or the data we process.

Any queries relating to this Notice should be addressed to the HR Department in the first instance. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK. This Notice was last updated in December 2024.