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Careers Privacy Policy

Clara-Pensions Group Limited

Careers Privacy Policy

1) Introduction

This privacy policy explains how Clara-Pensions Group Limited uses and looks after job applicants’ personal information.

This includes what you tell us about yourself and what we learn through the recruitment process. This notice also tells you about your privacy rights and how the law protects you.

Controller 

The Clara-Pensions Group is made up of different legal entities, including Clara-Pensions Group Limited and Clara-Pensions Limited (“Group”). This privacy policy is issued on behalf of the Group so when we mention “Clara”, “we,” “us,” or “our” in this privacy policy. We are referring to the relevant company in the Group responsible for processing your personal data.

This company is known as the ‘Data Controller’ for information collected about you during the recruitment and on boarding process.

You can find out more about Clara at https://clara-pensions.com/

 

2) How we use your information

Data Protection law says that we are allowed to use personal information only if we have a lawful reason to do so. This includes sharing it outside the Group. The law says we must have one or more of these reasons:

  • To fulfil your contract of employment or another contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. Even then, it must not unfairly go against your rights. Examples of legitimate Interests are detailed in the table below.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

  • For reasons of substantial public interest, or
  • For employment purposes, or
  • For the detection and prevention of fraud and crime, or
  • To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are, when that is one of the reasons.

Our reason What we do
To enter into and fulfil a contract of employment
  • Manage recruitment processes
  • Manage shortlisting
  • Obtain references and vetting
To fulfil another contract we have with you if your application is successful
  • Provide pension schemes and life assurance arrangements
  • Manage shareholding requirements
  • Manage colleague benefits
  • Apply colleague discounts
Our legal duty
  • Ensure rights to work
  • Comply with legal obligations and regulation
  • Provide information to regulators, courts or government bodies
Our legitimate interests What we do

  • Retain copies of the application
  • Ensuring security of premises, data and technology
  • Address complaints and queries
  • Market research and benchmarking purposes
  • Manage training and development
  • Support health and wellbeing
  • Monitor diversity and equality using your gender and social background information
  • Production of management information for data analysis
  • Ensure equality in our selection processes using social background information
  • To inform you of future opportunities with your agreement

Explanation of interest:

  • To comply with rules and regulations that apply to us
  • To protect our staff, customers and property from inappropriate access, damage, crime or fraud
  • To manage our staff as efficiently as possible
  • To communicate with you and comply with your instructions
  • To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit
Consent
  • When we rely on consent to process your information, we will advise you and inform you of how to withdraw your consent.

 

 

 

For processing special categories of personal data

Our reason What we do
Substantial public interest Monitor and manage diversity and equality by using racial, ethnic origin, religion, health and sexual orientation data
For employment purposes To make adjustments to accommodate health requirements during the selection process and, where relevant, in anticipation of commencing employment
For the prevention and detection of fraud and crime Use criminal records data to help detect, prevent and prosecute unlawful acts and fraudulent behaviour
Legal claims Use any special categories of data as needed to establish, exercise or defend legal claims
Consent When we rely on consent to process your information we will advise you and inform you of how to withdraw your consent.

 

Groups of personal information

We use many kinds of personal information, and group them together like this.

Type of personal information Description
Financial Details about your salary, bonus, pension and other benefits.
Contact Where you live and how to contact you.
Professional This includes details about your work or profession, education, skills, languages and qualifications.
Transactional Details about bank accounts, salary, pension and tax payments.
Contractual Details about performance of your employment contract.
Behavioural Details about how you act in the workplace, including performance and disciplinary action.
Technical Details on the devices and technology you use.
Communications What we learn about you from letters, emails, and conversations between us.
Social relationships Contact details of emergency contacts, next of kin and the beneficiaries of any occupational pension or insurance schemes.
Open data and public records Details about you that are in public records such as registers of bankruptcies, births, or public offices held, or information that is in the public domain, including on social networks.
Usage data Other data about how you use our systems and benefits you choose.
Documentary data Details stored in documents in different formats, or copies of them. For example your passport, drivers licence, or birth certificate.
Gender Information relating to your gender.
Gender identity Information relating to the gender you identify as.
Social background This includes details about your eligibility for educational financial support and family educational history.
Special categories of personal data Information about:

  • Racial or ethnic origin
  • Religious, philosophical and political beliefs
  • Sexual orientation or sex life
  • Health data
  • Criminal records of convictions and offences.
Consents Any permissions, consents, or preferences that you give us.
National identifier A number or code given to you by a government to identify who you are, such as a National Insurance or a Social Security number.

3) Where we get data from

Data you give to us:

  • When you apply for a role, or complete on boarding literature
  • When you talk to us or otherwise provide to us during the recruitment process
  • When you use our systems, tools and websites

4) Who we receive and share your personal information with

We may receive and share your personal information with other companies within the Group and these organisations:

  • Our suppliers, agents and advisers – such as IT provider – that provide services that help us to manage your recruitment, employment and benefits
  • Recruitment agencies
  • Social networks and published media
  • HMRC and other tax authorities
  • Disclosure & Barring Service, Disclosure Scotland, or Access NI for individuals located in Northern Ireland and relevant International governing body for individuals that have been resident outside of the UK within the last 18 months
  • Home Office and other government bodies
  • Credit reference agencies
  • Fraud prevention agencies
  • Your previous employers or referees
  • Courts and review panels
  • Law enforcement agencies
  • Vetting agencies
  • Pension and life assurance providers/trustees

Pre-Employment Background Checks

As part of our recruitment and onboarding procedures, we work with an external third-party supplier (HireRight) to conduct our pre-employment background screening. These checks are an essential part of our hiring process, helping us to verify the information provided by candidates and to meet our legal, regulatory, and risk management obligations.
The nature and extent of the checks may vary depending on the role, with enhanced checks undertaken for director-level and other senior or high-risk positions. Background screening may include the following:

  • Global Credit Search
  • Global Criminal Record Search
  • Directorship Search
  • Global Education Verification*
  • Global Employment Verification
  • Global Identity Check
  • Right to Work Documentation Verification (UK and global)
  • Global Sanctions and Enforcement Check
  • Professional Qualification Verification
  • Employment Gap Analysis
  • CV Analysis

*Education verification typically relates to the highest qualification obtained or those relevant to the position applied for.

Our third-party screening provider may, where appropriate, engage other specialist agencies to carry out specific elements of the screening process. These may include, but are not limited to, the Disclosure and Barring Service (DBS), credit reference agencies, and other regulated screening organisations with expertise in background verification. These agencies are carefully selected and are required to adhere to high standards of data protection and confidentiality.

All checks are conducted in compliance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You will be informed of the specific checks relevant to your role and asked to provide your explicit consent before any checks are undertaken.

All information gathered through this process is handled with the utmost care and confidentiality. Access to screening results is strictly limited to those involved in the recruitment process on a need-to-know basis, and all data is processed securely and lawfully.

5) Sending data outside of the EEA

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Follow your instructions
  • Comply with a legal duty
  • Work with our suppliers, agents and advisers who we use to help manage your recruitment, employment and benefits 
  • Sharing the data within the Group

If we do transfer information to our agents or advisers outside of the UK and EEA, we will make sure that it is protected in the same way as if it was being used in the UK and EEA. We’ll use one of these safeguards:

6) How long we keep your personal information

We will keep your personal information for the duration of the recruitment process and we may keep your data in line with our data retention procedures for one of these reasons: 

  • To respond to any questions or complaints
  • To show that we treated you fairly
  • To maintain records according to rules that applies to us
  • To retain your personal details on a prospect list for future role opportunities, subject to your agreement.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

7) How to get a copy of your personal information

You have the right of access to your personal data. You also have the right to transfer some information to other organisations. For more details on how to request a copy of your information please contact us in the following ways: 

Email address: [email protected] 

Postal address: 

Data Protection Officer
Clara-Pensions Limited
MYO St Paul’s
One New Change
London EC4M 9AF

8) Your data privacy rights 

You have several rights around use of your personal information. This section explains your data privacy rights and how to contact us about them. 

The right to rectification

We ask you to update your details yourself if you change things like your contact details, address or bank account. You should also do this if you think something is wrong or incomplete.

The right to erasure

You have the right to have your personal data deleted or removed if there is no reason for us to keep it, also known as ‘the right to be forgotten’. There may be legal or other official reasons why we need to keep or use your data. But please do let us know if you think that we should not be using it.

The right to restrict processing

You have the right to restrict processing of your personal information. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. You can ask us to do so if your personal information:

  • is not accurate
  • it has been used unlawfully 
  • it is not relevant anymore 
  • you have already asked us to stop using your personal information but you are waiting for us to tell you if we are allowed to keep on using it. 

If we do restrict your personal information in this way, we will not use or share it in other ways while it is restricted. 

The right to object

You have the right to object to us keeping or using your personal information. There may be legal or other official reasons why we need to keep of use your data. But please do tell us if you think we should not be using it.

The right to withdraw consent

You have the right to withdraw your consent for us to use your personal information at any time. This will only affect the way we use information when our reason for doing so is that we have your consent. 

You also have the right to make a complaint to us if you think there has been an infringement of data protection laws.

If you wish to exercise any of the rights set out above, please contact us.

9) How to contact us for more information

If you have any questions, or want more details about how we use your personal information, please contact us in one of the following ways: 

Email address: dat[email protected] 

Postal address: 

Data Protection Officer
Clara-Pensions Limited
MYO St Paul’s
One New Change
London EC4M 9AF

To make a complaint about how we’ve handled your information, contact us as set out above.

If you’re not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commission. Its contact details are:

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

Telephone number: 0303 123 1113 or 01625 545 700

https://ico.org.uk/concerns/

Last updated: December 2025