Privacy notice for candidates

Baillie Gifford & Co is a Scottish partnership headquartered at Calton Square, 1 Greenside Row, Edinburgh, United Kingdom, EH1 3AN. As a “data controller”, Baillie Gifford is committed to protecting the privacy and security of your personal information in accordance with all applicable personal data protection laws and regulations (including but not limited to, the UK General Data Protection Regulation (the “GDPR”) and the UK Data Protection Act 2018). This Privacy Notice describes how we collect, use and retain personal information for the purpose of recruitment.

If your application to work for us is successful, we will hold additional information about you as your employer in accordance with our Employee Privacy Notice, which will be provided at the relevant stage.

This privacy notice is not intended for individuals who previously invested directly with us through our Investment Trust ISAs, Share Plans or Children’s Savings Plans. Neither is it intended for those who subscribe to our marketing, invest in our OEICs or for our business contacts.

• If you are a former direct investor in our Investment Trust ISAs or Plans, please see the former investors privacy notice.
• If you subscribe to our marketing, please see the marketing recipients privacy notice.
• If you invest in an OEIC, please see the OEIC investors privacy notice.
• If you are a business contact, please see the business contacts privacy notice.

The kind of information we hold about you

We need to use your personal information to decide whether to enter into a contract of employment with you. In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you, to the extent permitted or required under applicable national laws.

• The information you have provided to us in your CV and covering letter
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, nationality, employment history, education, and qualifications
• Any information you provide to us during an interview and/or assessment process
• Your bank account details (if these are necessary to reimburse reasonable travel expenses)
• Social demographic data (UK applications only/see section below)

If your application progresses through the recruitment process, we will also collect, store, and use (depending on your location and nature of your role):

• Information about your credit profile
• Information about criminal convictions and offences
• Information contained in references (or work certificates in Poland) from previous employers
• Copies of right to work documentation and other immigration data, where required

We may also collect, store and use the following "special categories" of more sensitive personal information, to the extent permitted or if required under applicable national laws:

• Information about your race/ethnicity, sexual orientation or disability status, in order to ensure meaningful equal opportunity monitoring and reporting (carried out on an anonymised basis). If you do not want to disclose this information you can select the option ‘prefer not to say’ or skip the question.
• Information about your specific disability if you provide it because it is relevant to making appropriate adjustments to the recruitment process.

Social demographic data (UK applicants only)

We may collect social demographic data that you provide to us on a voluntary basis to allow us to ensure meaningful equal opportunity monitoring and reporting (on an anonymised basis) in the context of social mobility. We may collect, store and use the following data for this purpose:

• Information regarding your schooling
• Information relating to your individual circumstances - whether you have been eligible for free school meals, the highest level of qualification of your parent/guardian and/or their occupation

If you do not want to disclose this information you can select the option 'prefer not to say' or choose to skip the question. Neither disclosing nor withholding such information will have any impact on the assessment of your application.

Information about criminal convictions

Depending on your location and the nature of role which you are being hired into, we may be required to conduct a criminal record check or ask you to provide appropriate certification.

If this is required, during the recruitment process, we will outsource our vetting process (including checking criminal records) to a third-party provider. You will be asked to input your personal information to their portal. As a financial services firm operating in a highly regulated sector, Baillie Gifford needs a high degree of trust and confidence in all of our employees. This means that, as part of our pre-employment screening process, we carry out criminal record checks on all individuals joining the firm, if allowed under applicable law or regulation. These checks may be repeated during employment if required.

Unless relevant to the ongoing employment, data on criminal records will be deleted as soon as possible following recruitment or the decision not to recruit. Unless the provision of certain personal information is expressly stated to be voluntary, you are required to provide us with your personal information. Failure to provide the necessary information will preclude you from being eligible for a role with Baillie Gifford.

How your personal information is collected

In addition to information provided directly by you, we may obtain information from: recruitment agencies; Vero (in relation to background checks, including credit checks and criminal convictions); and your referees where required.

How we will use information about you

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role
• For speculative applications, to match you to appropriate vacancies
• Carry out background and reference checks, where applicable
• Communicate with you about the recruitment process
• Keep records relating to our hiring processes including equal opportunity monitoring and reporting, to the extent permitted or required under applicable national laws
• Comply with legal or regulatory requirements

If you fail to provide particular information which is necessary for us to consider your application, then we will not be able to process your application.

Data sharing

We may have to share specific and relevant components of your personal information with third-party service providers and other entities within Baillie Gifford, for the purposes of processing your application. We require third parties to respect the security of your data and to treat it in accordance with the law.

In particular, we may share your personal information with: Workday (HR Systems), Vero (pre-recruitment and employee vetting for regulatory roles), Sanctuary (search partner for certain graduate roles), QA (search partner for certain Modern Apprenticeship roles), Deloitte (visa, immigration, and tax services) and Shepherd and Wedderburn (legal services).

Transfer of personal data outside the UK/EEA

Due to the global nature of our business, your personal data may be transferred to, and processed by, Baillie Gifford entities outside the UK and/or the European Economic Area (EEA). Such personal data may also be processed by personnel operating outside the UK and/or the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure suitable safeguards are in place to protect the privacy and integrity of your personal data in such circumstances, including standard contractual clauses under Article 46.2 or an adequacy decision under Article 45 of the GDPR. You can obtain information and a copy of documentation relating to these safeguards by using the contact details at the end of this notice.

Data security

Preserving the security of your information is essential to ensure we meet legal, regulatory, and your own expectations, whilst maintaining high levels of confidence and trust. To support these objectives, Baillie Gifford has in place firm-wide policies and procedures covering information security to protect information and preserve the confidentiality, integrity and availability of the personal information we hold.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. If your application is unsuccessful, we will retain your personal information for a set period of time from the closing date of the vacancy. Please see the table below for the retention periods in your specific location. Where required by law, we may retain your application for a longer period than specified in the table for the establishment, defence, or exercise of legal claims.

Speculative CV’s will typically be retained for 12 months from the date of receipt unless prohibited by applicable national law.

Data retention periods

Employee Location	Early Careers from vacancy closing date	Experienced Hire from vacancy closing date
Canada	N/A	2 years
China	12 months	6 months
Germany	N/A	6 months
Hong Kong	N/A	6 months
Ireland	N/A	14 months
New York	N/A	12 months
Poland	N/A	6 months
Switzerland	N/A	6 months
UK	12 months	12 months

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information
• Request correction of the personal information that we hold about you if it is inaccurate
• Request erasure of your personal information if there is no good reason for us continuing to process it
• Ask us to stop processing personal information (where we are relying on a legitimate interest) if you wish to object to processing on this ground
• Request the restriction of processing of your personal information
• Request the transfer of your personal information to another party

If you have any questions about this Privacy Notice, please email hr@bailliegifford.com

If you have further questions about how we process your personal information, or to exercise one of the rights described above, please email dataprotection@bailliegifford.com

If you are unhappy with our response, you can then make a complaint about how we are holding or processing your personal information to the UK Information Commissioner's Office (ICO) or the relevant national regulator in your location.