Privacy Policy

Revised: May 2, 2024.

1. Introduction

Qatalyst Partners Limited (“Qatalyst“, “we” or “us“) has issued this Privacy Policy (“Policy“) to describe how we collect, process and share personal information about job applicants (referred to as “you“) during the recruitment process for a role at Qatalyst, the purposes of the processing, and the rights that you have in connection with our processing. “Applicant” is used in this Policy to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

This Policy does not apply when you are visiting Qatalyst’s website. Please see our online privacy policy for more information about how we process personal information in that context: https://www.qatalyst.com/privacy-policy/. This Policy also does not apply when you are visiting or submitting any information to dartmouthpartners.com. Please see Dartmouth’s privacy policy for more information about how Dartmouth processes personal information in that context: https://www.dartmouthpartners.com/privacy-policy

If you have any comments or questions about this Policy, please contact us at the contact details in Section 12 below.

This Policy does not form part of any contract of employment or other contract for services with us or indicate any form of employment, worker or other contractual relationship with us.

2. Types of personal information we collect

As part of the recruitment process, we will process personal information about you. If you do not provide us with the personal information necessary to manage your application or the recruitment process, we may not be able to consider your application.

The types of personal information we may process include:

  • Identification Information – such as your name, title, gender, photograph, signature, date of birth, national identifiers;
  • Demographic and Work Authorisation Information – age, information relating to immigration or visa status (including right to work information), disability and other personal information necessary for us to make reasonable adjustments as part of the job application process (if provided by candidate).
  • Background Check Information (where permitted by and in accordance with applicable law) – credit reports, educational and professional history, criminal background checks.
  • Contact Details – such as home address, telephone/email addresses, emergency contact details.
  • Position and Competency Information (including Professional History, Skills and Certifications) – such as current job title/position, academic/professional qualifications, education, CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), residence history, outside business activities, transcripts and employment references, details of your nominated referees (including their name, contact details, employer and job role), details of any previous applications made to or employment history with Qatalyst or its group companies.
  • Other Information Voluntarily Provided by You – for example, through assessment centres, exercises and interviews.

Qatalyst does not discriminate, either directly or indirectly, on protected grounds: race (including colour, nationality, ethnic origins and national origins), sex, gender reassignment, marriage and civil partnership, pregnancy and maternity, sexual orientation, religion or belief, age, or disability in any area of recruitment. Save where we specifically request it, we ask that you avoid submitting personal information that may qualify as sensitive personal information under applicable law, except where such sensitive personal information is legally required. Sensitive personal information may include personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. Sensitive personal information may also include genetic and biometric information (for the purpose of uniquely identifying a natural person), data concerning health, sex life, sexual orientation or personal information relating to criminal convictions and offences or related security measures. We will process sensitive personal information in accordance with applicable law.

We may request sensitive personal information relating to you: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider reasonable adjustments for the recruitment process and/or subsequent job role.

3. Sources of personal information

Usually, you will have provided the personal information we hold about you. There may be situations where we collect personal information or sensitive personal information about you from other sources. For example, we may collect the following personal information (where permissible and in accordance with applicable law):

  • references provided by referees;
  • other background information provided or confirmed by academic institutions and training or certification providers;
  • criminal records data obtained through criminal records checks;
  • information provided by background checking agencies and other external databases (for example, credit reference agencies and professional / other sanctions registries);
  • information provided by recruitment or executive search agencies; and
  • information as may be available from publicly available sources (such as professional social media accounts like LinkedIn).

4. Purposes and lawful bases for processing personal information

We process your personal information for the reasons listed below based on one or more of the following reasons (or “lawful bases”): (i) because we are required to do so by applicable law such as applicable immigration and employment laws; (ii) where it is necessary to take steps at your request before entering an employment contract; (iii) because such information is of particular importance to us and we have a specific legitimate interest to process it including to protect the rights and interests of Qatalyst, our employees and others, as permitted by applicable law (where we rely on our legitimate interests to process personal information, we will consider this carefully and ensure these rights are not overridden by your rights); (iv) where the processing is necessary to protect the vital interests of any person; or (v) where we have your consent. Where we have requested your consent to process your personal information, you have the right to withdraw your consent at any time.

Where we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear to you at the relevant time and advise you whether the provision of your personal information is mandatory or not, as well as the possible consequences if you do not provide your personal information.

If you are accepted for a role at Qatalyst, the personal information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Policy.

We process your personal information primarily for recruitment purposes, including for considering your employment with us. We also process your personal information to comply with applicable law, where it is in our legitimate business interests to process your personal information and to protect the rights of Qatalyst, you or others. Further information about how we process personal information is set out below:

  • To respond to your inquiries, assess your application and communicate with you about your application. In reviewing your application, we may assess your skills, qualifications and background for a particular role, verify your information, carry out reference or background checks (as applicable) and to generally manage the hiring process and communicate with you about it. We will engage in these activities to comply with a legal obligation and/or, based on our legitimate interests and/or where necessary to take steps at your request prior to entering an employment contract;
  • To conduct background checks and right to work checks if we offer you a position. We will engage in these activities to comply with a legal obligation and/or based on our legitimate interests and where there is a substantial public interest in preventing and detecting unlawful acts or where the processing is necessary to meet our obligations under employment law, social security and social protection law (provided, however, such backgrounds checks are typically run through a third-party administrator);
  • To preserve our other legitimate interests, for example, for our administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business within Qatalyst based on our legitimate interests;
  • To facilitate your expense claims. We will engage in these activities based on our legitimate interests;
  • To comply with applicable law, respond to requests from public and government authorities, and cooperate with law enforcement. This can include laws and authorities outside your country of residence. We will engage in these activities to comply with a legal obligation and/or based on our legitimate interests;
  • For other legal reasons, such as to enforce our terms and conditions, and to protect our rights, privacy, safety, or property, and/or that of our employees, affiliates, you, or others. We will engage in these activities to comply with a legal obligation and/or, based on our legitimate interests and/or where necessary to protect your vital interests or that of another person;
  • In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  • To monitor the diversity of Applicants and make reasonable adjustments to our job application process, in accordance with applicable law. We will engage in these activities to comply with a legal obligation and/or based on our legitimate interests and when we have your explicit consent or where the processing is necessary to meet our obligations under employment law, social security and social protection law (as applicable).

5. When we share your personal information

We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. We provide access to personal information within Qatalyst and our affiliated US companies and parent company, Qatalyst Partners LP and Qatalyst Partners LLC and Qatalyst Group LP, when our employees or agents have a need to know the personal information for the purposes described above. This may include individuals responsible for assessing your application and providing IT support. Whenever we permit a third party to access your personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Policy and that the security and confidentiality of the information is maintained.

Third parties that we share personal information with include:

  • members of the Qatalyst Group around the world for administration purposes;
  • recruitment or executive agencies involved in your recruitment;
  • background checking or other screening providers and relevant local criminal record checking agencies;
  • data storage, shared services and recruitment platform providers;
  • IT developers and support providers; and
  • third parties who provide support and advice including in relation to legal, financial/audit, management consultancy, insurance, health and safety, security and intel and whistleblowing/reporting issues.

We may also share personal information in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any insolvency, bankruptcy or similar proceedings).

6. Transfer of personal information abroad

We may need to transfer personal information to countries other than the ones in which the information was originally collected. When we export personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. Specifically, we transfer personal information from Qatalyst Partners Limited to our US affiliates and parent, Qatalyst Partners LP and Qatalyst Partners LLC and Qatalyst Group LP, respectively, when necessary to fulfil the purposes set out in this Policy.

For transfers to the US and other jurisdictions not considered adequate by the UK government, we have put in additional safeguards to protect your personal information, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You may request a copy of these safeguards by contacting us using the contact details provided at Section 12 below.

7. Data retention periods and security

Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Policy or as otherwise required by applicable laws. When determining these retention periods, we take into account: the period we have an ongoing relationship with you (including whether you are accepted for a role at Qatalyst); the length of time we need to retain personal information to comply with a legal or compliance obligation to which we are subject or for audit purposes; and when it is advisable for us to retain personal information to defend or bring potential legal claims.

We may delete personal information about you (including your CV/résumé) from our database at any time and for any reason. Therefore, please retain your own copy of the personal information provided to us.

The security of your personal information is important to us. We employ organisational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all personal information processing, and we cannot guarantee the security of your personal information.

8. Your data privacy rights

You may request to exercise the rights available to you under applicable data protection laws as follows:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at Section 12 below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the contact details provided at Section 12 below.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. The data protection authority for the UK is the Information Commissioner’s Office, whose website is available here: https://ico.org.uk/.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. Your obligations

Please keep personal information up to date and inform us of any significant changes to your personal information. Any information you provide to us when applying for a job must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights. If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

10. Current Personnel of Qatalyst

If you currently work for Qatalyst, you must be eligible to apply for a different position within Qatalyst, to apply for a new role. If you accept such a position, the terms of your employment, compensation and benefits may change. Please consult with your HR contact for the new position concerning application eligibility and policies applicable to that position.

11. Updates to this Policy

Updates to this Policy may be made periodically to reflect necessary changes in our privacy practices. You will be informed of any updates in a manner consistent with distribution of important compliance policies and procedures. This Policy was last updated and became effective on the date posted at the top of this Policy.

12. Contact details

Please address any questions or requests relating to this Policy to [email protected] or to Qatalyst’s Chief Compliance Officer, [email protected].