This policy lets you know how GBST Holdings Limited and its affiliates and subsidiaries (“GBST” or “we”) collect and use your personal information in connection with GBST's Recruitment Portal and GBST’s recruiting efforts more generally, both online and offline.  This policy describes the broadest potential use of personal information; we may make less use of your personal information than is described here.

Your provision of personal information in connection with the recruiting or job application process confirms your consent for GBST to collect that information and to use, transfer, retain and share it with third parties as specified in this policy.

Collecting Personal Information.  You may provide personal information to GBST.  GBST's Recruitment Portal asks for certain data, including educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to apply for a job vacancy advertised.  You also may choose to provide GBST additional information, such as your CV, resume, or transcripts; employment references and other related information.  In addition, GBST may collect information from third parties, for example, in connection with a background or employment check and/or an employment reference.

Pre-Employment Screening.  As part of our recruitment process we also conduct pre-employment checks on candidates applying for roles with GBST in accordance with regulatory, local legislative and geographic requirements.  You will be able to consent to these checks separately, but please be aware that we will need to provide some of your personal information to our third-party providers so that GBST to set up these checks.

GBST’s web sites, including GBST’s Recruitment Portal, may use cookies and other electronic communication protocols.  For further information please consult the GBST UK/EU Privacy Policy.

Sensitive Personal Information and Supporting Diversity at GBST

 At GBST we aim to offer an inclusive workplace where employee differences, such as gender, age, cultural background, disability, sexual orientation, family and caring responsibilities and region are valued and leveraged for individual, business and organisational success. We may ask you to provide sensitive personal data during the application process. The information is used to report on the diversity of our candidate base at an aggregate level only. This information will not be visible to GBST's selection panelists. To the extent that information you provide contains details of your racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health or condition; sexual orientation; commission or alleged commission of an offense or related proceedings; job evaluations or educational records, you expressly authorise GBST to handle such details as specified in this policy. 

Voluntary Disclosure.  Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide to GBST; please note that if you decide not to provide information, it may affect our ability to consider you for employment.

Using Personal Information.  The information may be used to communicate with you, to manage GBST’s recruiting and hiring processes, for example to:

• assess and administer your application or interest in employment in accordance with the GBST Group’s standard practices, including conducting psychometric testing and reference checks;
• communicate with you in relation to your application or registration of interest;
• conduct any pre-employment screening (if an offer of employment is to be made);

• monitor and review our recruitment practices; and

• for compliance with corporate governance and legal and regulatory requirements.

If you accept an offer of employment with GBST, the information provided in your application and/or candidate profile and any other information collected during the application and selection process will become part of your employment records and other GBST company policies will be applicable i.e. Staff Privacy Policy to your personal information.

Data Recipients and Sharing with Third Parties.  GBST may share your personal information internally and with service providers and other third parties as necessary in connection with recruiting, employment, corporate governance, acquisitions, legal or regulatory requirements, to respond to requests from public and government authorities (including public and government authorities outside your country of residence) and for national security and/or law enforcement purposes.  GBST requires that its service providers and such other third parties keep your personal information confidential and that they only use the personal information in furtherance of the specific purpose for which it was disclosed.  GBST and its service providers may use your personal information in an anonymised format (in a form in which your identity cannot be determined) for other purposes not specified above, including in the development and testing of products and services.

Security and Confidentiality.  Except as otherwise stated in this policy or as required for legal or regulatory purposes, GBST treats your personal information as confidential and will not disclose it to third parties without your consent.  GBST maintains, and requires its services providers to maintain, reasonable administrative, physical, and technical controls designed to protect the confidentiality and security of your personal information.  GBST employees who may have access to personal information are required to keep that information confidential.

GBST may employ security procedures at its facilities and on its computer systems to monitor and maintain security, including the use of closed circuit television (CCTV).  Any monitoring of GBST facilities, systems or assets is performed in accordance with applicable law.

Retention and Access.  If your application is unsuccessful or we currently have no roles for which you are suitable, we may retain your personal information using GBST Recruitment Portal in case a more appropriate opportunity becomes available.  Please contact us at either careers@gbst.com or alternatively, at privacyofficer@gbst.com if you do not want us to retain your personal information and we will remove your application or registration of interest from our system.  You may also contact us at the above email addresses if you want to make amendments, corrections or deletions to your personal information because such information is inaccurate, outdated or incomplete.  To the extent permitted or required by law, GBST may delete data at any time; accordingly, you should retain your own copy of any information you submit to us.

You may access and correct personal information you have submitted online using GBST’s Recruitment Portal .  You may submit other requests by filling out the inquiry form or by contacting the GBST Privacy Officer using the details provided below. 

Your Responsibilities.  You are responsible for the information you provide or make available to GBST, and you must ensure it is honest, truthful, accurate and not misleading in any way.  You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable.  Further, if you provide any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for GBST to collect and use that information as described in this policy.

Cross Border Transfers

GBST is a global corporation and has developed global data security practices designed to ensure that your personal information is appropriately protected.  Please note that personal information may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this policy.

Due to the nature of GBST, it is common for personal information that is collected by the prospective employing GBST entity to be disclosed to other entities within the GBST Group.  These entities may be in another jurisdiction, and personal information may be transferred to other jurisdictions whereas different data protection laws may also apply.  However, your personal information will be stored on servers located in the EU therefore the data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679)) (“GDPR”) will apply.

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

GBST group companies have entered into and executed a Framework Agreement in relation to personal data transfers within the GBST Group which allows for the processing of your personal information and which also incorporates the European Union Model Clauses requirements for the transfer of your personal information.

Dispute Resolution

If you have any complaints regarding our compliance with this policy, you should first contact GBST’s Privacy Officer.  GBST will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information in accordance with this policy. If you have an unresolved privacy or data use concerns that we have not addressed satisfactorily you also have the right to lodge a complaint with your local supervisory authority.  For the UK, this is the Information Commissioner whose contact details are:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

General.  We may update this policy from time to time.  Please also take a moment to review the GBST Personal Data Protection Policy for more information on GBST’s obligations and your rights regarding GDPR.   In the event GBST makes material changes that reduces your rights or GBST’s obligations under this policy, we will post a prominent notice in this section of this policy notifying users when it is updated.  If you have any questions or concerns about this policy or its application, or if you believe your personal information has been used in a way that is not consistent with this policy or your specified preferences, please contact us by the following methods:

By Email to GBST’s Privacy Officer    privacyofficer@gbst.com

By Mail (within UK/EEA)          GBST Wealth Management Limited

8^th Floor Linen Court

10 East Road

London  N1 6AD

United Kingdom

By Mail (outside the UK/EEA)  GBST Holdings Limited headquarters are located at:

Level 4 West Tower

410 Ann Street

Brisbane QLD 4000

Australia