Senior Portfolio Compliance Guidelines Analyst, Asset Management

Who are we?

The Return Hub, 40 Gracechurch Street, London, EC3V 0BT, +44 203 907 8040

Registered Address: Springfield House, Springfield Road, Horsham, West Sussex, United Kingdom, RH12 2RG

We provide a unique executive search service to clients looking to recruit mid-senior financial services professionals who have been on a career break, are looking to pivot or have been on a different path for a while.

We also provide The Career Academy which is a free career development platform with resources aimed at helping individuals promote their careers.

What does this policy cover?

We at The Return Hub take your personal data seriously. This policy:

sets out the types of personal data that we collect about you
explains how and why we collect and use your personal data
explains how long we keep your personal data for
explains when, why and with who we will share your personal data;
sets out the legal basis we have for using your personal data;
explains the effect of refusing to provide the personal data requested;
explains the different rights and choices you have when it comes to your personal data; and
explains how we may contact you and how you can contact us.

What personal data do we collect about you?

We collect the information necessary to be able to find and match available opportunities with candidates and further information needed to assess eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment, details of activities during any career-break, and references.

We may also collect sensitive personal data about you, in the form of background reference checks, remuneration and compensation details passport scans and details. We ask for your consent to collect sensitive personal data from you, and further process this data.

If you are receiving coaching from us, we will also process any additional information that you choose to provide to us during the course of the coaching.

Where do we collect personal data about you from?

The following are the different sources we may collect personal data about you from:

Directly from you. This is information you provided if you are a business contact of The Return Hub or if you signed up to join The Return Hub, expressed an interest in our services, or if you registered for The Career Academy or one of our free resources such as a webinar or a networking event.
From an agent/third party acting on your behalf
Through publicly available sources. We use the following public sources:
- LinkedIn
- Google
By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.

How and why we use your personal data?

We rely on our legitimate interests to:

Use your personal data to match your skills, transferrable skills, experience, knowledge and education with a potential employer or to help find the right candidate for the employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner and will seek your consent to do this.
We will contact you by telephone, email or social media if we have an opportunity that we think might be suitable for you or someone you know.
We will communicate with you by mailchimp email to keep you updated with our monthly newsletter if you have opted to receive our resources – you can unsubscribe from these at any time.
We will communicate with you on email about resources, events and webinars that we think will be directly relevant and useful to you.
We may contact you to to ask or survey your opinion to assist us with the delivery of our services and for research purposes.
We use other personal information you provided us with on an aggregated anonymous basis to understand the composition of our network. We do not disclose any of this information on an individual basis.

How long do we keep your personal data for?

We keep your information in line with our retention policy as follows:

Candidate data: Is reviewed on an ongoing basis. We set to review your data with you at minimum every 18 months to see where you are on your journey back to work and ensure our service is still relevant to you and that your data is still accurate.

Client contact details: 5 years reviewed annually.

Should the data no longer be relevant we delete your record. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:

(a) our contractual obligations and rights in relation to the information involved;

(b) legal obligation(s) under applicable law to retain data for a certain period of time;

(d) statute of limitations under applicable law(s);

(e) (potential) disputes;

(f) if you have made a request to have your information deleted; and

(g) guidelines issued by relevant data protection authorities.

Who do we share your personal data with?

If you are a member of The Return Hub, your personal data may be shared with a client who is seeking personnel to ascertain if you are a good fit for an available position. We may also conduct checks on you to verify the information you have provided and where we do this we may share your information with the referees you have provided us with.

In order to service our IT processes, your data is also accessible to our IT service contractors and consultant researchers.

As part of Returner strategies, we also have access to Associate Coaches – we share your data with them with your consent in order that they can do their job effectively.

What legal basis do we have for using your information?

For members of The Return Hub, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.

If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as national insurance records, evidence of the right to work in the UK, past salary and remuneration details that you or others provide about you. In that case we ask for your consent before undertaking such processing.

For clients and business associates, we may also rely on our processing being necessary to perform a contract for you or with you for example in contacting you. For prospective candidates, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.

If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as national insurance records, evidence of the right to work in the UK, past salary and remuneration details that you or others provide about you. In that case we always ask for your consent before undertaking such processing.

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.

Do we make automated decisions concerning you?

Where any automated processing is employed, the decision making process is always done by a human.

Do we use cookies to collect personal data on you?

To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.

Do we transfer your data outside the EEA?

No, we do not transfer personal data out of the EEA.

What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.

Rights	What does this mean?
1. The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. The Return Hub will provide information in plain English on how will process and store your data as part of our data collection activities. This is why we’re providing you with the information in this Policy.
2. The right of access	You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. Please contact us with your name and email at info@thereturnhub.com to make a Subject Access Request.
3. The right to rectification	You are entitled to have your information corrected if it’s inaccurate or incomplete. You can either correct your personal information held with us using our profile update functionality, or contact us at info@thereturnhub.com with the detail you would like amending.
4. The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. Please contact us with your name and email at info@thereturnhub.com to make a deletion request.
5. The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. Please contact us with your name and email at info@thereturnhub.com to exclude your details from some or all of our processing activities.
6. The right to data portability	You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. Please contact us with your name and email at info@thereturnhub.com to request a digital copy of your data.
7. The right to object to processing	You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities). Please contact us with your name and email at info@thereturnhub.com to make a request to restrict processing of your data
8. The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator. You can make a complaint about our data processing directly to info@thereturnhub.com or to the UK Information Commissioner
9. The right to withdraw consent	If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. Please contact us with your name and email at info@thereturnhub.com to make a deletion request.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

baseless or excessive/repeated requests, or
further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know. If you prefer us to not to contact you for any reason you can email us at info@thereturnhub.com to let us know you exact wishes.

How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us at: info@thereturnhub.com

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