Privacy Policy
Last updated: October 2024
This Privacy Policy explains what Neptune North Limited (“NNL”) does with personal data you supply to the firm in circumstances where you apply for a job at the firm either directly or via a third party recruiter.
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The policy describes how NNL collects, uses and processes your personal data, and how, in doing so, it complies with its legal obligations to you. Your privacy is important to NNL, and the firm is committed to protecting and safeguarding your data privacy rights.​
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The UK GDPR and Data Protection Act 2018 are applicable to the processing of personal data by NNL.
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We may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as NNL will publish any changes here.​
If you are dissatisfied with any aspect of NNL’s Privacy Policy, you may have legal rights and, where relevant, we have described these below.
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Identity & contact details of data controller
Neptune North Limited
16 Abbey Meadows
Morpeth
England
NE61 2BD
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Please contact a representative of NNL with any queries or concerns regarding the handling of your personal data: careers@neptunenorth.co.uk
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What kind of personal data does NNL collect?
In order to assess you for employment opportunities, NNL needs to process certain information about you. NNL only asks for details that will genuinely help to assist in this process, such as your name, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks) social security number as well as verbal and written references. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health (such as where we collect diversity data as outlined below) and any criminal convictions. NNL may also, with your consent, collect information relating to your health, age, gender identity, sexual orientation, religion and ethnicity in order to monitor our diversity, equity and inclusion (D,E&I) efforts in the context of our recruitment practices and to provide reasonable accommodations and adjustments to candidates with disabilities. This information is collected on an entirely voluntary basis.
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How does NNL collect Personal Data?
NNL may collect personal data through a range of means. These may include:
a) direct interactions (where you provide personal data to NNL through telephone or email correspondence or other direct methods of communication, including applications for prospective employment);
b) from third parties such as third party recruitment firms in the case of prospective employees;
c) other publicly available sources (such as a websites (for example, LinkedIn) or publicly-
available registries (for example, FCA or other regulatory registers)); and
d) your personal referees or former colleagues now working at NNL may share personal information about you with NNL.
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How does NNL use your personal data?
Your personal details are used by NNL to help us (a) assess your suitability for roles that you have applied for either directly or via a recruiter; (b) provide any reasonable accommodations or adjustments where relevant; (c) monitor our D,E&I efforts in our recruitment practices; (d) carry out background checks, verification and referencing on you as a candidate (e) carry out NNL’s obligations relating to any potential contracts entered into between NNL and you; and (f) to comply with legal or regulatory obligations applicable to NNL.
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We are entitled to use candidate data in these ways because:
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we need to in order to take steps in preparation for entering into a contract with you, in particular to consider you for a position at NNL;
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to the extent this is required by applicable data protection laws and regulations, we have separately asked you for your consent and provided information as to what happens if you do not give consent;
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we have legal and regulatory obligations that we have to discharge;
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we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or
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the use of your personal data as described is necessary for our legitimate business interests, such as:
o allowing us to effectively assess your skills, qualifications and/or the strength and merits of your application and
your suitability for the role applied for;
o allowing us to effectively verify your information;
o allowing us to effectively and efficiently administer and manage the operation of our business;
o ensuring a consistent approach to the recruitment of NNL personnel worldwide; or
o being able to contact you in relation to your application and the recruitment process.
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Please note, if your application is successful and you are subsequently offered and accept employment at NNL, the information we collect during the application and recruitment process will become part of your employment record.
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The provision and processing of your personal data is necessary for NNL in the context of your potential employment. Without the ability to process your personal data, NNL would not be able to assess you for employment at the firm. NNL will not discriminate automatically against any subject of a criminal record check on the basis of a conviction or other information revealed.
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Who does NNL share your personal data with?
Your personal data will be shared internally with any of NNL’s group companies for the purposes of candidate selection and appointment. Your personal data will also be shared with inter alia third party suppliers who provide screening and testing services to the firm as well as legal, tax and HR advisers and third party recruiters. If references are sought NNL will also share your personal data with previous employers and referees.
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Transfer of Personal Data outside the UK and European Economic Area
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NNL may transfer your personal data to other NNL companies based outside of the UK and the European Economic Area
(the “EEA”).
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Where NNL transfers personal data outside the UK and EEA, it will seek to ensure a similar degree of protection is afforded by ensuring that personal data is transferred only to persons in countries outside the UK and EEA in one of the following circumstances.
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To persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
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To persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the UK government.
In other circumstances the law may permit us to otherwise transfer your personal data outside the UK and EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.
You can obtain more details about the protection given to your personal data when it is transferred outside the UK and EEA by contacting us in accordance with the “Identity and contact details of data controller” section.
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How does NNL safeguard your data?
NNL has in place security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These security measures include procedures to deal with any suspected personal data breach. NNL will notify any affected person and any applicable regulator of any personal data breach in circumstances where they are required to do so by applicable law.
How long does NNL retain your personal data for?
If your candidature does not proceed to employment with, or hiring by, NNL it will retain your personal details for a period of twelve months after the position you may be suitable for is filled. After that point NNL’s policy is to delete your personal data from its systems unless NNL believes in good faith that the law or other regulation requires NNL to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation) or if NNL considers that you may be suitable for an alternative role. If you do receive an offer of employment with NNL, further details shall be provided to you in or around the time of your hire, regarding how your personal data may be used for the purposes of your employment.
How can you access, amend or take back the personal data that you have given to NNL?
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You have various rights in relation to your personal data. To get in touch about these, please email careers@neptunenorth.co.uk. NNL will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that NNL will keep a record of your communications to help it resolve any issues which you raise.
You have the right to obtain information regarding the processing of your personal data and request access to any personal data concerning you that NNL is processing. Whilst NNL takes efforts to ensure that all personal data that it processes is accurate and up-to-date, you may ask NNL to rectify any inaccurate or incomplete personal data concerning you and NNL will do so without undue delay. In the event NNL relies on consent to process any of your personal data, you have the right to
withdraw your consent to the processing of your personal data at any time. Please note, however, that NNL may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, NNL may need to retain personal data to comply with a legal obligation and as noted in this privacy notice, NNL relies mainly on its legitimate interests to process your personal data. You may, in certain circumstances, request that NNL erase your personal data and/or request that NNL restricts, or you object to, NNL’s processing of your personal data if certain criteria apply. Please note that there may be circumstances where you ask us to erase your personal data, or where you object to or request we restrict, our processing of your personal data, but we are legally entitled to retain it. You have the right in certain circumstances to data portability. This means that, in those circumstances, you have the right to receive from NNL any personal data concerning you in a structured, commonly used and machine-readable format, and may request that NNL transmit it directly to another data controller, where technically feasible. Please note that this right only applies to personal data which you have provided directly to NNL. Should you have any concerns about how NNL processes your personal data you should contact NNL at the email address above. You also have the right to lodge a complaint with the Information Commissioner’s Office if you think that any of your rights have been infringed by us.​