Last updated on 23 December 2022
How we collect information
It applies to information we collect about:
- Visitors to our website
- Clients using our services
- Our legal obligations in relation to Financial Crime Prevention and other obligations applicable to financial services providers
- Job applicant and our current and former employees
It would be important to note that any personal data received from the customer will be processed only for the purposes of preventing money laundering or terrorist financing, or as permitted under an enactment other than these Regulations; or the relevant person has obtained the consent of the data subject to the proposed use of the data (as per MLR 2017 Regulation 41(4)).
Visitors to our websites
When someone visits www.choice-forex.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Information we collect to personally identify you will solely be used to action your request to contact you. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who call our office
When you call Choice Group, we do not need other information, other than what is essential to identify you and ensure we are able to help client’s queries, and on simple terms, speak to you.
People who email us
We use Bitlocker to encrypt and protect email traffic. If your email service does not support encrypted email, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
We do not use live chat services; we believe in old fashioned conversations, so please refer to the “People who call our office”.
Security and performance
Choice Group uses a third-party service EC2IT to help maintain the security and performance of its website. To deliver this service it processes the IP addresses of visitors to the Choice Money website.
Please refer to the following link to understand EC2IT data processing arrangements https://www.ec2it.co.uk/it-support-news-and-blog/gdpr/
Social media contacts
We will not ask you to contact us using Social Media; whilst we appreciate its importance in today’s marketing activities, we do not believe in you information, requests, queries, etc. having to be processed by an undetermined number of third parties, across several jurisdictions, so we can be contacted or just answer you queries. We contact our clients or third parties via email or telephone only.
Complaints and Data Subject Access Requests (DSAR)
When we receive a or a DSAR from a person we make up a file containing the details of the complaint/request. This normally contains the identity of the complainant and any other individuals involved.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure and information for AML purposes will be retained for at least six years. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries or DSARs are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
People who use Choice Group services
Choice Group offers various services to the public. We use a third party to provide KYC and financial crime remediation services, provided by reputable third parties such as ComplyAdvantage.
We have to hold the details of the people who have requested the service in order to provide it, along with the personal data of the individuals who are being subjected to financial crime and/or KYC remediation services/checks. We only use these details to provide the service the person has requested.
Service providers reporting a breach
Public electronic communications service providers are required by law to report any security breaches involving personal data to the ICO. We will advise if our providers, and other service provider who we may engage reports a data breach.
Job applicants, current and former Choice Group employees
Choice Group is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at email@example.com.
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format. We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for but it might affect your application if you do not.
If you email us, your data will be collected directly by us via our email provider. We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our HR team will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities.
Our hiring manager’s shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
- Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
- Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
- You will be asked to complete a criminal records declaration to declare any unspent convictions.
- We will provide your email and personal details to the relevant Government service who will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
- We will contact your referees, using the details you provide in your application, directly to obtain references.
- We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).
If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments
- Emergency contact details – so that we know who to contact in case you have an emergency at work
- Membership of a Pension scheme – so we can send you a questionnaire to determine whether you are eligible to re-join your previous scheme.
Post start date
Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest. If you complete a declaration, the information will be held on your personnel file.
How long is the information retained for?
If you are successful, 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 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 6 months from the closure of the campaign. Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign. Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.
How we make decisions about recruitment?
Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.
You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing firstname.lastname@example.org
Under GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you.
Use of data processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Access to personal information
Choice Group tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you, we will:
- give you a description of it
- tell you why we are holding it
- tell you who it could be disclosed to
- let you have a copy of the information in an intelligible form.
To make a request to Choice Group for any personal information we may hold you need to put the request in writing addressing it to email@example.com.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting at the above.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate issues or situations in line with Financial Crime Acts we may need to share personal information with the organisation concerned and with other law enforcement bodies.
You can also get further information on:
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics
- our instructions to staff on how to collect, use and delete personal data
- how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated in December 2022.
Complaints or queries
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Choice Group’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact us at firstname.lastname@example.org. Please note, our Data Protection Officer is Harpreet Jagdev.
How to contact us
34 Curzon Street, London, W1J 7TS.
Or via email at email@example.com.