Candidate Privacy Policy

Neilson Financial Services is a global employer and has employees based in various locations around the world. This policy is directed at individuals interested in career opportunities at either Neilson Financial Services Ltd (UK), Neilson Financial Services Inc. (Canada) or Neilson Financial Services Pty Ltd (Australia). Unless specified, the information contained within this policy applies to applicants based in each of these jurisdictions.

This privacy policy has been provided to let you know how we use and look after your personal information during our recruitment process. This includes what you tell us about yourself, what we learn about you from third parties we work with and companies who introduce you to us, and the choices you have.

The policy also tells you about your privacy rights and how the law protects you when (i) we contact you, (ii) you contact us (iii) you use our online recruitment portal.

We promise to:

• Keep your data safe and private
• Give you ways to manage and review your choices
• Not sell your data to anyone else

How we use information about you

We collect personal information from you when you show interest in career opportunities with Neilson Financial Services. We may also collect your personal details from other sources, to help us with your application (more details can be found under the heading “Where we collect your personal information from”). We have provided examples below of the ways we may use your personal information and why.

Where we collect personal information from

We collect personal information you provide when you:

• apply for a career opportunity at Neilson Financial Services.
• use our website or those provided by our third-party service providers, on our behalf.
• provide us with your curriculum vitae (“C.V. or Resume”) or a link to your LinkedIn profile.
• write to us, email us or call us about a job opportunity.
• interact with our social media page or social media job advert.

We may also receive data from:

• companies/third parties that introduce you to us – When companies introduce you to us and share your details, this will usually be because you’ve provided your consent for them to do so. We conduct due diligence on our partners to ensure they have a lawful reason to share your data with us. We may also receive your data from employees who refer you to us.
• third parties we work with – for example, we may receive information about you from third parties whom we have asked to conduct background checks on you.

The categories of personal data that we may obtain from you or third parties are:

• Basic Personal Information – this includes your name, date of birth and residency status.
• Contact details – this includes your postal address, email address and telephone number.
• Employment and Education History - this includes previous employment, education, training, work experience, professional qualifications, languages spoken, salary expectations.
• Application information – this includes references from previous employers and referee details, interview notes and recordings from video interviews, and job preferences such as location, working hours and flexibility.
• Background information –information obtained to verify your personal information or conduct additional checks on your background, in accordance with applicable law. This may include information about your residency and right to work in a specific location, criminal records checks and credit checks (where applicable), and any additional screening as and where required.
• Profiles, Cookies and similar technologies - Any profile you create or information you provide when you connect to our internet domains, mobile and telephone services. (we do this using cookies, further details can be found under the heading “Cookie Policy”)

When you provide us with personal data about others, you must (unless we agree otherwise): (a) inform the individual about the content of this Privacy Policy and any other applicable privacy notices provided to you; and (b) obtain their permission (where possible) to share their Personal Information with us in accordance with this Privacy Policy and other applicable privacy notices.

Who we share your personal information with

We may use and share your personal information with third party service suppliers we partner with to administer our recruitment activity.

Neilson uses a third-party supplier, SmartRecruiters, to provide its applicant tracking system (“ATS”) platform. Where Neilson Group job applications are administered on SmartRecruiters ATS software application, Neilson Financial Services remains responsible for the security of your data, and this privacy policy applies.

If you apply for a job at Neilson Financial Services, SmartRecruiters may contact you to ask whether you would like to set up a profile on their platform. If you agree to this, SmartRecruiters will be responsible for how they collect, store, and use your personal information, in connection to your profile on their platform. SmartRecruiters’ privacy policy can be found at www.smartrecruiters.com/legal/general-privacy-policy/ which also provides information on how to opt out of this processing activity.

In addition, Neilson Financial Services uses third parties to verify your information, conduct pre-employment screening, and background checks, in accordance with applicable law. This may include sharing your data with:

• Screening service suppliers such as firms that provide background checks, task-based assessments, and video screening.
• Previous employers for obtaining references and verifying your employment history.
• Regulators, government agencies and statutory bodies as required under applicable law.
• Firms required to sponsor your application for employment, where applicable.

We may also share your personal information with regulators, government agencies and statutory bodies, to fulfil a legal or regulatory obligation, assist with an investigation or court request, or demonstrate compliance.

If we are required to assist with travel arrangements relating to your job application, we may share your details with transport providers and/or travel agencies.

If we sell our company or part of it, we may share your information with the purchaser, to continue to offer the services described within this policy.

How we use your information to make automated decisions

To assess your suitability for the role you have applied for, we may use pre-defined search parameters to filter applicants most likely to meet our criteria. Although this aspect of the process does not involve human input, the information is presented to our internal recruitment team and hiring managers, before a decision is taken to progress with the application. Care is taken to ensure that any aspects of data processing that involve automated decision making are tested regularly, to ensure they operate as intended.

If you choose not to give personal information

We always aim to give you a clear choice before we process your data, and act within your expectations. When you show interest in a career opportunity with Neilson Financial Services, we’ll ask you for your permission to process your data to administer the application process.

If you choose not to give your permission, we will not be able to take your application any further. Any data collection that is optional and not strictly required to administer your application will be made clear to you, at the point of collection.

Removing your consent

For any processing activity where we have received your consent, you have the right to withdraw the consent at any time. We aim to make this as straightforward as it was to provide it in the first place. If you have created a profile with SmartRecruiters, you can remove your consent on your profile by clicking the link "edit consent info" at the top of your profile page.

You can also withdraw your consent and/or update your choices by contacting our recruitment department using the following details below:
recruitment@neilsonfs.com

If you have given your consent for us to contact you about future job opportunities related to your application, we will also include an unsubscribe link in any email and/or electronic message we send, enabling you to opt out of these communications.

How long we keep your personal information

Neilson Financial Services maintains strict data retention policies which govern how long we will keep your personal data for. We will only keep your information for as long as we need it for the purpose(s) for which it was collected, to meet our obligations to you and the rules that apply to us.

We will retain your personal data whilst your application is ongoing. If your application is successful and you become employed with Neilson Financial Services, you will become subject to our Group Data Security Policy. All information processed during your application will be stored in your personnel file and retained in accordance with this policy.

If your application is unsuccessful, we will retain your personal data for 3 years to:

• Provide you with information about related job opportunities at Neilson Financial Services which might be of interest to you (with your consent).
• To demonstrate we have met our legal obligations throughout the application process and treated you fairly.
• To respond to litigation or any other form of dispute, legal right or obligation.

International Data Transfers

Neilson Financial Services may transfer personal data internationally, within its group of companies, and third-party service providers. This means that your personal information may be accessible to law enforcement and regulatory authorities in these jurisdictions.

However, if we transfer your personal information to third parties or companies within our group internationally, we will ensure that those parties protect your personal information in a manner which is consistent with this privacy policy. Where we transfer personal data internationally, Neilson Financial Services ensures that appropriate safeguards are in place in connection with such transfer and that all necessary consent has been obtained.

UK based candidates

When you apply for a job at Neilson Financial Services Ltd and throughout the application process, Neilson Financial Services Ltd acts as Data Controller under the UK General Data Protection Regulation (UK GDPR), when it processes your personal data.

This means that we are responsible for ensuring that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with that regulation and all other applicable data protection laws and regulations.

Neilson Financial Services is registered with the Information Commissioner’s Office under registration number ZA125017. If you would like more information about our data protection policy, please contact us using the details shown on our website www.neilsonfs.com.

Data Protection Law allows us to use personal information only if we have a clear reason to do so. This includes how we share data outside of Neilson Financial Services. To meet this requirement, we will only process personal data in the following circumstances:

• To fulfil and administer a contract we have with you;
• When it is in our legitimate interest;
• When we have a legal duty to;
• When you consent to it

There are circumstances where an alternative legal basis allows us to process personal data legitimately. Where we rely on an alternative legal basis for processing personal data, we will tell you what it is.

Your Rights

Individuals have a number of rights in connection with their personal information. These rights only apply in certain circumstances and are subject to certain exemptions. These rights are noted below.

All enquiries in respect of these rights will be handled by Neilson Financial Services, however, where necessary, we will liaise with other parties with whom we have shared your personal information (see "Who we share your personal information with" above) when dealing with your request.

How to get a copy of your personal information

You can access the personal information we hold on you by contacting us by email or post using the following details:

Data Protection Officer at Neilson Financial Services Limited, 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS Email: customerservice@neilsonfs.com

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. We will take reasonable steps to check its accuracy and correct it.

If you want us to stop using your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as the "right to object", "right to erasure" or the "right to be forgotten".

However, there may be occasions when we will not be able to delete personal information if a legal or regulatory requirement prevents us from doing so.

Restricting the use of your personal information

You can ask us to restrict the use of your personal information if:

• it has been used unlawfully, however, you do not want it to be deleted
• it is not relevant anymore, but you request it is kept for use in legal claims
• you have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.
• it is not accurate

Data portability

You can ask us to provide you with personal information you have given us, in a format that can be read by a computer. You can also ask that we share your data in this format, to someone else.

Opting out and withdrawing consent

You can opt out of hearing from us about future job opportunities that might be of interest and withdraw consent that you’ve given by contacting us. Please see the “Removing your consent” section of this policy.

How to Complain

Please contact our Data Protection Officer if you are unhappy with how we have used your personal information. To contact us about any of your rights set out in this Privacy Policy please write or call our Data Protection Officer at Neilson Financial Services Limited, 2 Windsor Dials, Arthur Road, Windsor, SL4 1RS, email customerservice@neilsonfs.com. Please provide your full name, email address and date of birth when contacting us.

You also have the right to complain to the Information Commissioner’s Office.

The ICO's address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: www.ico.org.uk

Canada based candidates

By providing us with your personal information during the job application process you will be deemed to agree to the terms of this privacy policy. We therefore encourage you to read this privacy policy carefully before you provide your personal information to us.

To evidence our commitment to managing your personal information properly we have developed and follow a privacy code which is based on the ten fair information principles contained in the Personal Information Protection and Electronic Documents Act (PIPEDA).

Accountability

We are responsible for your personal information which is in our control. We have therefore appointed a Privacy Officer to oversee and hold us accountable for our management of your personal information.

If you wish to contact our Privacy Officer, you can do by writing to us at Neilson Financial Services Inc. PO Box 64004, Royal Bank Plaza, Toronto, Ontario, M5J 2T6, emailing us at customerservice.ca@neilsonfs.com or calling us at 1-844-990-4466.

Identifying Purposes

We will always identify the purposes for which we may use and disclose your personal information before or at the time of its collection by us. These purposes are referred to as the "identified purposes".

Consent

Except as otherwise permitted or required by law, we will only collect, use or disclose your personal information with your permission.

Limiting Collection

We will only collect your personal information in a way which is fair and lawful, and we will only collect as much of your personal information as is necessary for the identified purposes.

Limiting Use, Disclosure and Retention

Except as otherwise permitted or required by law, we will only use and disclose your personal information for the identified purposes. We will also retain your personal information only for as long as is necessary for the identified purposes.

Accuracy

We take steps to ensure that the personal information you give to us is recorded accurately and completely, and that any changes required to be made to your personal information are made promptly.

Safeguarding Information

We will always take steps to protect your personal information which are proportionate to the sensitivity of that information. We have appropriate safeguards in place to protect your personal information against loss, theft, and unauthorized disclosure, copying, use or modification. We also strictly limit access to your personal information to those of our employees, partners and service providers who require access to it.

Openness

We will always make detailed information about our policies and procedures for managing your personal information readily available to you.

Individual Access

Subject to exceptions permitted by law, we will comply with any request you make to us to access the personal information we hold about you and be informed of the existence, use and disclosure of that information by us. You may also challenge the accuracy and completeness of the personal information we hold about you and have that information updated as appropriate.

Challenging Compliance

You may challenge our compliance with these principles or raise a complaint about our management of your personal information by contacting our Privacy Officer. We will always treat such challenges or complaints seriously.

Australia based candidates

Neilson Financial Services Pty Ltd is committed to ensuring the protection of your personal information, throughout the job application process. This Privacy Policy outlines how we meet our obligations under The Privacy Act 1988 (Privacy Act) and comply with the Australian Privacy Principles (APP) which sets out standards, rights and obligations in relation to handling, holding, accessing and correcting personal information.

How to access your personal information

You can access the personal information we hold on you by contacting us by email, post or by calling us using the details stated within the “How to Contact Us” section below.

When making a request, please provide your name, contact details and the information you’d like to access.

Correcting your personal data You also have the right to correct the personal information we holds about you if it is inaccurate, out of date, incomplete, irrelevant or misleading. If you wish to do so, please contact us using the details below.

How to Complain

if you are unhappy with how we have used your personal information or would like to find out more about our privacy practices or information set out in this Privacy Policy, you can contact our Privacy Officer using the details below.

How to contact us

Post: Neilson Financial Services Pty Ltd, Level 4, 115 Pitt Street, Sydney 2000.

Email: customerservice-au@neilsonfs.com

Cookie Policy

Neilson Financial Services is committed to protecting your privacy and we promise to treat it securely, fairly and lawfully.

When we collect any personal information through our website and technology platforms, we will be transparent about what we collect, why we collect it and how we intend to use the data.

Protecting our customers is at the heart of everything we do at Neilson Financial Services and protecting your information is no exception.

We use cookies on our website and other similar technologies to collect anonymous data so that we can improve and enhance your experience when you use our services. These cookies allow us to:

• Make our website work as effectively and efficiently as possible.
• Enhance your browsing experience
• Arrange content to match your preferred interests more quickly
• Collect statistical information to provide us with information on how our customers use our website and our products.

We will collect information about how you use our website to:

• Remember how far you are in the online application form you are completing
• Provide advertising that is more relevant to you when you are visiting our, or other, websites promoting our products for example via retargeting cookies
• Track the effectiveness of our online and offline marketing campaigns.

This Cookie policy relates to our use of Cookies and similar technologies, on this website. Relevant information about how Neilson Financial Services uses cookies on its other websites, can be found on each of these branded sites, respectively.

How to manage and switch off cookies

Your web browser provides settings that allow you to manage or switch off cookies. If you do switch off cookies, remember that you may not be able to use all the services on our website. You can find out more about managing and switching off cookies at the independent website allaboutcookies.org. You can update your cookie preferences using this link.

What are Cookies

"Cookies" are small piece of text files which are sent to your browser and stay on your computer or mobile device when you visit our website. Cookies do not damage your device they are used to ‘remember’ you when you visit our website again. Cookies alone cannot be used to identify you.

A cookie will transport information about how you use our website to us. The cookie does not keep any of the data it collects.

Cookies are often referred to as session or persistent cookies, depending on how long they are used:

• Session cookies only last for your online session and disappear from your computer or device when you close your browser.
• Persistent cookies stay on your computer or device after the browser has been closed and last for the period specified in the cookie. These persistent cookies are activated each time you visit the site where the cookie was generated.

In addition to how long a cookie is kept on your computer, a cookie is then divided into four types:

Strictly necessary cookies These cookies are essential to enable services you have specifically requested such as requesting a quote and/or purchasing a product.

Performance cookies

These cookies collect information about how you use our website, for instance which pages you visit most often, and if you experience error messages. These cookies don't collect information that identifies you. All information is aggregated and therefore anonymous. They are only used to improve your experience whilst visiting our website.

Apart from cookies we also use local storage and tags to help us enhance your browsing experience.

• Local storage is like a cookie, except the information collected by local storage is not sent to an internet server unless there is a specific reason for us to store the data collected (i.e. for analytics purposes).

Like cookies, local storage is stored locally on your machine, within your browser like cookies, history, saved pages, etc. Local storage contains ‘name/value’ pairs (i.e. postcode / SL4 1RS, surname / ‘Smith’) and a web page can only access data stored locally within its domain.

• Tags are a small piece of code which is placed on our website and collects data. This code would only collect data on our website. A tag will not be stored on your browser; however, it may use a cookie which could be placed on your browser.

SmartRecruiters

Neilson uses a third-party supplier, SmartRecruiters, to provide its applicant tracking system (“ATS”) platform. Where Neilson Group job applications are administered on SmartRecruiters platform, SmartRecruiters use cookies and similar technologies to collect anonymous data to authenticate your access to various areas of their websites, tailor its content to your preferences, and analyse web traffic in general.

More information about SmartRecruiters' cookie policy can be found by clicking the link below:
www.smartrecruiters.com/legal/general-privacy-policy

You'll be given the choice to consent to non-essential cookies SmartRecruiters use before you access SmartRecruiters website.

Last Updated: March 2024