Recruitment Privacy Notice

GAM respects your privacy rights. This Recruitment Privacy Notice demonstrates our commitment to your privacy and sets out how we handle and protect your personal data in connection with GAM’s recruitment process.

"Personal Data" means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and or through alternative channels (e.g. professional recruiting firms).

Your personal data is processed by the GAM entity you apply to and this will be the data controller of that personal data. We may pass all or part of your data between other relevant GAM group companies to the extent permitted under local law.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment and our recruiting programs and events. We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable legislation in which case, the applicable legislation will prevail.

By submitting your personal data to us, you acknowledge that:

• You have read and understand this Privacy notice and the use of your personal data as set out herein;
• Your personal data may be transferred and processed within the group. Please refer to the ‘International data transfer’ section of this notice for further details;
• You are not compelled to provide any requested information to us but if you are unable to provide us with the information requested we may be unable to assess your appropriateness for the job you have applied for;
• Information you submit must be true, complete and not misleading. Should the information provided be inaccurate, incomplete, or misleading, this may lead to a rejection of your application during the recruitment process;
• This Privacy Notice does not form part of any contract of employment offered to candidates by GAM.

Personal data we collect about you

The types of personal data that we collect from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the jurisdictions involved.

We will collect personal data from you when you apply for a role with us, such as but not limited to, your name, address, contact information, work and educational history, entitlement / eligibility to work documentation, employment reference. We also may collect such personal data about you from third parties, such as professional recruiting firms, your references, prior employers, GAM employees with whom you have interviewed, and employment background check providers.

We do not collect special categories/sensitive personal data from you (e.g. personal data relating to racial or ethnic origin, political or religious opinion, membership of a trade union, physical or mental health or condition or sexual orientation), unless required to do so by applicable laws.

Basis for the use of your personal data

We collect and use your personal data for human resources and business management purposes:

• identifying and evaluating candidates for current and future job opportunities (we do not make recruiting or hiring decisions based on automated decision-making);
• record keeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements;

Data processing

Your personal data may be accessed by HR and interviewers working in the country where the position for which you are applying is based, as well as by HR and interviewers working in different countries within GAM. Individuals performing administrative functions and IT personnel within GAM may also have a limited access to your personal data to perform their assigned responsibilities.

We may also share your personal data with other third party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Where reasonably necessary or required to do so, we may disclose these details to third parties in relation to law enforcement or regulatory investigation and or for the purpose of conducting any pre-employment checks.

Data retention

We retain personal data for no longer than is allowed under applicable legislation and, in any case, no longer than such personal data is necessary for the purpose for which it was processed.

If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with applicable data protection requirements.

If we do not employ you, we may retain your personal data for 18 months for the purpose of monitoring recruiting activity with us, unless such processing conflicts with the requirements of applicable legislation in which case, the applicable legislation will prevail.

How we protect your personal information

We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable local law.

We have implemented generally accepted standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorised personnel of GAM and of our third party service providers are provided access to personal data, and these employees and third party service providers are required to treat this information as confidential.

International data transfer

Whenever GAM transfers your personal data out of the jurisdiction it was collected in, it will ensure an adequate degree of protection is given to the personal data.

Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that has been taken to protect personal data during such transfer. Please contact us at dataprotectionofficer@gam.com.

Your rights

Depending on the location of the relevant GAM entity, you may have certain rights in relation to your personal data. Please be aware that certain exceptions apply and so you will not be able to exercise these in all situations. Your rights are as follows.

1. Subject Access: You have a right to be provided with access to any data held about you by GAM, generally within 1 month of your request.
2. Rectification: You can ask us to have inaccurate personal data amended.
3. Erasure: You can ask us to erase personal data in certain circumstances and we will take reasonable steps to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of it.
4. Withdrawal of consent: You can withdraw any consents to processing that you have given us and prevent further processing if there is no other ground under which GAM can (and does) use to justify the processing your personal data.
5. Restriction: You can require certain personal data to be marked as restricted whilst complaints are resolved and also restrict processing in certain other circumstances.
6. Portability: You can ask us to transmit the personal data that you have provided to us and we still hold about you to a third party electronically.
7. Raise a complaint: You can raise a complaint about our processing with the data protection regulator in your jurisdiction.
8. Prevent processing: You can require GAM to stop any processing based on the legitimate interests ground unless GAM’s reasons for undertaking that processing outweigh any prejudice to your data protection rights.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, your objection could mean that we are unable to perform the actions necessary to achieve the purposes set out in this notice. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

If you would like to exercise your rights, please contact us at dataprotectionofficer@gam.com . We will respond to your request in writing as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request.

This notice was last updated on 13 September 2023.