Recruitment Privacy Policy

We are BGV Investment Management Limited (“BGV”, “we” or “us”). Our company registration no. is 10499434 and our registered address is at 63/66 Hatton Garden Fifth Floor Suite 23, London, England, EC1N 8LE.

We are the controller of the personal information we process about you. We are registered with the Information Commissioner’s Office (ICO): ZA362735.

This privacy policy describes how we how we collect, use and otherwise process personal information relating to you, or that you provide to us:

● when you visit or use the website at (the “Website”) or submit your application via a recruitment agency or Applied with a view to applying for a job;

● when you contact us (by email or telephone), for example to submit an application or query in respect of any job vacancies; and/or

● when you undertake any recruitment assessments.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information.

If you have any questions about how we use your personal information, please contact:

1. Equal Opportunities

BGV is an equal opportunities employer and a company committed to diversity. This means that we are committed to ensuring all job applicants receive equal treatment and are not discriminated against on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age.

2. The types of personal information we collect

We collect and use the following information about you:

● Identity Data including your gender, first name, surname, any applicable national identification number, and any type of government-issued IDs (e.g. passport details).

● Contact Data including your address, email address, and telephone numbers.

● Transactional Data including information about our business dealings, transactions and interactions with you.

● Technical Data including your IP address, device type, browser type, usage details and broad geographical location when you visit or engage with our Website or social media accounts.

● Usage Data including information about how you use our Website.

● Marketing and Communications Data including your preferences in receiving marketing from us, including news and updates, and your communication preferences.

● Recruitment Data including your CV, information held on your social media accounts such as LinkedIn, data relating to your performance during the application process and information provided by recruitment agencies, third party references, health information to make reasonable adjustments, information from anti-money laundering and sanctions checks, information from criminal records checks, any relevant recruitment test results.

We will indicate where any personal information we have requested is mandatory. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances, this may mean we are unable to provide you with a certain service.

3. Special Categories of Data

For the purposes of engaging with us, you might also share with us special categories of personal information relating to your:

● race or ethnicity;

● disability records;

● sex life or sexual orientation;

● criminal convictions and offences.

You may share such information with us for diversity monitoring purposes or to enable us to fulfil our obligations to you (e.g. to make reasonable adjustments so you can attend interviews with us). Your personal information will be collected and processed in accordance with data protection laws and securely with safeguards in place to protect your rights and freedoms.

4. If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to hire you into the relevant vacancy).

5. How we use your personal information

We use personal information relating to you that we collect, or that you provide to us, for the following purposes:

● To inform you when we advertise a job which we consider may be of interest to you based on information you have provided to us;

● To progress your application, improving the application process, and for carrying out pre-employment checks;

● To make job offers to you where you are the successful candidate;

● To ensure that content from the Website is presented in the most effective manner for you;

● To fulfil any legal or regulatory requirements, if necessary;

● To deliver, manage and improve our Website;

● To assist you and respond to your enquiries and provide assistance;

● To comply with the law; and

● To perform our day-to-day business activities.

6. Lawful basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the legal basis will be one of the following.

● Consent. This applies where, for example, we obtain your consent to certain marketing communications.

● Our legitimate business interests. Where it is necessary for us to perform our business activities, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.

● Performance of an agreement with you. For example:

▪ where you have provided your information in order to receive details in relation to our open positions and job vacancies;

▪ to employ or engage you as a potential employee of our business.

● Special Categories of Data. We are required to have an additional legal basis to process special categories of personal data (including criminal offence information). We usually rely on the following:

▪ the processing is necessary for the establishment, exercise or defence of legal claims;

▪ the processing is necessary for reasons of substantial public interest (e.g., to comply with the law and prevent unlawful acts); or

▪ where we have your explicit consent.

● Compliance with the law. Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

7. How we share your personal information with third-parties

We may share your personal information with third-party vendors, service providers, contractors, or agents ('third-parties partners') who perform services for us or on our behalf and require access to such information to do that work. This includes any recruitment agencies who have submitted your details to us.

We have contracts in place with our third-party partners, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us without our approval. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

If you would like to apply for a job at BGV, we will direct you to our online application system provided by Applied which will collect the application information which is used to assess your suitability for the role you have applied for.  Applied will hold the information you submit but BGV will have access to it in order to review your application. Here is a link to Applied’s privacy policy ( We might ask you to fill in an online application form provided by Applied; participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of twelve months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

We may disclose your personal information to other third parties in the following cases:

● If we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

● If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or

● To protect our business and enforce our rights (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party partners to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

8. Cookies

Our Website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. For further information on how we use cookies on our Website, please read our Cookie Policy available here.

9. Where we store your personal information

In the event that we transfer your personal information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU and UK “Standard Contractual Clauses”) to ensure your information is subject to adequate safeguards in the recipient country.

If you are located in the UK or EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

10. Your Rights

We take your privacy very seriously and want you to be aware of your rights, as follows:

● you have the right to request (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;

● you have the right to request the rectification or removal of your personal information or restriction of the processing of your personal information;

● where processing of your personal information is either based on your consent or necessary for the performance of an agreement with you and processing is carried out by automated means, you have the right to request the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another business, where technically feasible;

● where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;

● you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement;

● you have the right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information, and to balance our legitimate interests in carrying out the processing and your objection to this processing;

● you have the right to object to processing your personal information for direct marketing purposes; and

● you have the right to lodge complaints before the competent data protection regulator, the UK Information Commissioner’s Office, and you may do so at

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Please send us an email at if you would like to exercise any of your rights.

11. External Links

Although the Website only looks to include safe and relevant external links, users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.

The Website may, from time to time, contain links to and from the websites of our partner networks.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

12. Data Security

We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We take steps to ensure that your personal information is treated securely and in accordance with this privacy policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, for example, by encryption or by using pseudonymisation, we cannot guarantee the security of your information transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organisational measures designed to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

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.

We will, from time to time, include links to and from the websites of our partner networks, advertisers, social media platforms and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

13. How long we keep your personal information

We retain your information for as long as it is necessary to provide you with the service we supply to you or to fulfil our obligations to you. Where we do not need your information in order to provide the service or to fulfil our obligations to you, we retain it only for so long as we have a legitimate business purpose in keeping such data.

Our standard retention periods are as follows:

● when you visit our Website, we retain information on our server logs for up to two years;

● when you make an enquiry or correspond with us for any reason, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for twelve further months after which point we will delete your information as long as you have not requested we delete your information at any point before this retention period finishes;

● if you are successful in respect of a job vacancy, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment with us plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

● if you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for up to twelve months from the closure of the recruitment campaign. Information generated throughout the assessment process, for example, interview notes, is retained by us for up to twelve months following the closure of the campaign whether you are successful or not.

However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations (such as tax or accounting) or where it is necessary for the establishment, exercise or defence of legal claims.

If you request that your personal information be removed from our databases and/or systems, please note it may not always be possible to completely delete all your personal information due to technological and legal constraints. However, we will take such steps as are reasonable to securely delete such information or to store your information in an aggregated and anonymised format.

Should you request additional services from us, you will be authorising the extension of the data collection and/or processing purpose as a result.

14. Information relating to children

This policy is not directed at children under the age of 18. If you believe that we have personal information about or collected from a child under the relevant age, please contact us at

15. Queries and complaints

In the event that you wish to discuss, or make a complaint about, how we process your personal information, please contact us in the first instance at and we will endeavour to deal with your request as soon as possible.

This is without prejudice to your right to submit your complaint to the relevant data protection authority.

16. Changes

We will generally notify you of any material changes to this policy, through a notice provided via the Website or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the end of this policy, which reflects the effective date of such policy. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.

Last updated: 15th September 2022