Privacy Policy

Our approach
This privacy notice sets out how CFC Underwriting Limited (registered company number 03302887) headquartered at Second Floor, 85 Gracechurch Street, London EC3V 0AA and our group companies (together referred to as “we”, “us”, “CFC”) collect, store and process your personal data when you apply for a position at CFC.

Who collects your data
The data controller will be the CFC group company that your application for employment or temporary work relates to, these are set out below:
  • CFC Underwriting Limited, 85 Gracechurch Street, London EC3V 0AA,
  • CFC Security Limited, 85 Gracechurch Street, London EC3V 0AA,
  • CFC Europe S.A, Levels 20 & 21 Bastion Tower,  5 Place du Champ de Mars, 1050 Brussels, Belgium,
  • CFC Australia Pty Ltd, Suite 22 Level 2, 130 Bundall Road, Bundall QLD 4217,
If you have any questions about this notice, please contact compliance@cfc.com

What information do we collect
We collect the following information about you during the recruitment process:
  • Information provided in your curriculum vitae, application form, covering letter and during the interview process including: your name, date of birth, age, gender, home address, personal email address, education, qualifications and work experience details, and references.
  • Your driver’s licence or passport to verify your identity.
  • Information collected or created by us during the recruitment process including: correspondence between us, interview notes and test scores (where applicable). 
  • Information about criminal convictions:  For designated roles we will carry out background checks and checks on publicly available social media as part of the recruitment process.
  • Special categories of personal data including:  Racial and ethnic origin information and information relating to disabilities, religious beliefs or sexual orientation, physical or mental health  information and immigration/naturalisation records (if this discloses racial/ethnic origin information).
Why we use your personal data
We use the personal data collected from you for the following reasons: 
  • It is necessary for us to do so before entering into a contract with you,
  • We need to process your information in order to comply with a legal or regulatory obligation,
  • We or a third party have a legitimate interest in processing your personal data, to ensure: 
    • the effective administration and management of the recruitment process, 
    • we hire a suitable individual for a role and are able to make an informed recruiting decision, 
    • to verify the information you provide to us,
    • deal with disputes and accidents and take legal or other professional advice, 
    • ascertain your fitness to work.
Why we use special category personal data
We will process your special categories of personal data (1) to consider whether we need to provide appropriate adjustments during the recruitment process and to ascertain your fitness to work; (2) for equal opportunity monitoring purposes; or (3) to comply with any legal or regulatory obligation.

We will use special categories of personal information collected about you because: (1) we need to do so to carry out our legal obligations; (2) it is necessary for the establishment, exercise or defence of legal claims in relation to court cases; (3) there is a substantial public interest; (4) it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

Information about criminal convictions
As part of the recruitment process for designated roles, and if you are successful during the initial stages we (or our third party background check provider) may ask you for information in relation to criminal convictions and carry out criminal background checks.  We use this information and these checks (1) to assess your suitability for a regulated role; (2) to protect your interests, our interests and third party interests; (3) because it is necessary in relation to legal claims. We are allowed to use your personal information in this way where you have provided your consent.

Sharing your information
We may share information about you with the following third parties: (1) employment agencies, (2) Pinpoint our HR and recruitment system provider, (3) background check and online test providers including Vero Screening Ltd, located at Princes House, Queens Road, Brighton, BN1 3XB, who we have engaged to conduct pre-employment background checks, (4) credit reference agencies (5) regulators and competent authorities, and (6) within our group for administration, accounting and reporting purposes.

We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software) located at One Waverly Place, St Helier, Jersey, JE1 2PP, to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions.
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.

Where information may be held
Information may be held at our offices and those of our group companies (see table above), and third party agencies, service providers, representatives and agents as described above.

The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.

International data transfers
To the extent necessary, your personal data may be transferred and/or disclosed within the CFC Group, as may be required during the recruitment process. This may include transfers to servers and databases outside the country where you provided us with your personal data. Where we need to send data internationally we always consider our statutory obligations and rely on appropriate safeguards to ensure that your personal data is adequately protected. 

CFC has an intra-group data sharing agreement in place, which incorporates the appropriate standard contractual clauses to lawfully facilitate the transfer of personal data outside the UK and the EEA.

How long we keep your information
We will retain your personal information for the duration of the recruitment process and for the length of any applicable limitation period for claims which might be bought against us later. If you are successful in applying for a position, your personal information will be retained for a further period, as set out in our Employee Privacy Notice.

Your rights
Under the UK GDPR and the GDPR, you have the right to access, rectify, port or erase your personal data. You also have the right to object to and restrict certain processing of your personal data. This includes the right to object to our processing of your personal data where we are performing a task in the public interest or pursuing our legitimate interests.

To exercise your rights, please contact compliance@cfc.com

Data security
CFC takes the integrity and confidentiality of personal data very seriously. Personal data shall only be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing, and against accidental loss or damage. CFC is committed to ensuring that appropriate security is in place to prevent any personal data from being accidentally or deliberately compromised. A range of organisational and technical security measures have been put in place to protect data - for example, access controls and firewalls are reviewed periodically by all entities, and CFC Underwriting Ltd holds the Cyber Essentials Certification.

How to complain
If you have any questions, queries or concerns about this privacy notice, please contact compliance@cfc.com

General 
This notice may be amended by CFC at any time at our sole discretion. You can always find the latest version of this notice on our website.

Where you apply for an opportunity posted by us, these privacy notice provisions will apply to our processing of your personal information, in addition to any other privacy notice available on our website.