Legal and Privacy

UK Recruitment Process Privacy Notice

Last Updated: April 6, 2022

This Privacy Notice describes how Silver Lake Europe LLP (“Silver Lake” or “we”) collects and uses the personal data of prospective personnel for Silver Lake and its portfolio companies in connection with recruitment by the firm (“Prospects” or “you”). Silver Lake is the data controller in respect of Prospect personal data.

If at any point you have questions about this notice or how we will treat your personal data, you should contact us using the details at the end of this notice.

Personal Data We Collect About You

We may collect (directly or indirectly), store, and use the following personal data about Prospects:

  • Personal details and characteristics including your name, address, and previous addresses, birthplace and date, phone numbers, e-mail address, passport details, photographs, and birth and marriage certificates.
  • Information contained in your C.V. and covering letter or provided as part of a background, reference, or credit check, including occupational details, current job title, current job description, previous employment details, office location, education details, qualifications, credit history, and other information from our application form.
  • Economic, financial, and insurance information including historic salary, benefits and incentives, income and financial information, tax situation, historic insurance package, personal accounts, and holdings.
  • Information about your use of technology resources including IP address.
  • Your communications with us including information you provide to us during interviews.
  • Tests or qualification exam results from any assessments that are required to work with us.

We may also collect (directly or indirectly), store, and use information that may identify or infer information about you in connection with more sensitive types of personal data including:

  • your race or ethnicity, religious beliefs, sexual orientation, political opinions and contributions, and trade union membership if you provide it to us.
  • information about your health, including any medical condition, health and sickness records.
  • your history, if any, of criminal convictions and offences.

You may be required to provide certain personal data to Silver Lake so that we may consider your suitability. If you fail to provide any personal data that is required, we may be unable to continue evaluating your suitability.

How We Collect Personal Data

We typically collect personal data about Prospects from the following sources:

  • you directly.
  • other Silver Lake affiliates.
  • recruitment agencies we collaborate with to fulfil vacancies, from which we may receive information including your resume/C.V., current and past employment, and other qualifications.
  • professional background check providers.
  • credit reference agencies.
  • your named referees, former employers and other references, from whom we collect information about your previous employment and suitability for the role you are applying for.
  • publicly accessible sources, including the internet and financial regulator registers, from which we collect information about your qualifications, regulatory authorisations, and news items involving you.

How We Use Your Personal Data

We use the personal data that we collect, subject to applicable law and regulations, in the following ways:

  • Recruitment: managing and administering recruitment processes, carrying out background checks, making travel arrangements, assessing your skills, qualifications, and suitability for the vacancy you are applying for, communicating with you about the recruitment process, making offers to successful Prospects, personnel onboarding, and keeping records related to our hiring process to monitor and ensure fairness in our practices. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business and recruiting personnel for Silver Lake and its portfolio companies.
  • Legal and compliance: compliance with legal and other requirements such as immigration, record-keeping, and reporting obligations, reviewing HR processes, political contributions, responding to legal process such as subpoenas and court orders, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures. We process personal data for these purposes on the basis that we are required to do so by law or it is necessary for the establishment, exercise, or defence of legal claims.
  • Communications, facilities and emergencies: facilitating communications with you, protecting the health and safety of anyone visiting our premises, and safeguarding office equipment, facilities, and other property. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business, and administering, maintaining, and ensuring the security of our IT systems and premises.
  • Sensitive information: We may also collect certain types of sensitive personal data for specific purposes, including the collection of health or medical information for accessibility and ‘fit for work’ purposes and diversity-related personal data (such as gender, race, or ethnicity) for equal opportunity monitoring and reporting purposes. We do not collect your sensitive personal data unless we are required or permitted to do so by applicable law including in order to carry out our legal obligations or exercise rights in connection with your potential employment, it is needed in the public interests (such as for equal opportunities monitoring), or (in limited circumstances) you have, in accordance with applicable law, provided your explicit consent.
  • Criminal convictions information: Depending on the role you apply for, we may need to collect information about your criminal convictions history during the application process, if we intend to offer you employment (conditional on checks and any other conditions, such as references, being satisfactory).  Where the law allows or requires us to, we will carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for employment with us.  For example, we will need to carry out a Standard Disclosure and Barring Service Check for those wishing to work in our London office that will be discharging certain functions regulated by the Financial Conduct Authority.  We will inform you directly where we need to perform criminal convictions checks on you for your application.  We process personal data for these purposes on the basis that it is necessary for compliance with our legal obligations, where applicable, or on the basis of your explicit consent.

Data Sharing

We may share your personal data with Silver Lake Technology Management, L.L.C. and its portfolio companies for the purposes described in this Notice.

We may share personal data with service providers that perform services on our behalf such as payment service providers, benefits service providers, analytics providers, and hosting providers. As required by applicable law, we permit them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal data about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement or other governmental authority, a subpoena, court order, or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose Silver Lake to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will take appropriate steps to ensure it is adequately protected in compliance with the UK GDPR. We will usually do this by entering into standard contractual clauses (approved by the UK Information Commissioner’s Office) for data transfers with the recipient of your personal data.

You may request a copy of the safeguards that we have put in place in respect of cross-border transfers of personal data by contacting us as described in the ‘How to Contact Us’ section below.

Data Retention

Your personal data is retained for the duration of the relevant recruitment processes/discussions and as long as necessary thereafter to fulfil the purposes described above, which may be for up to six-years.

Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required by applicable law.

Retention periods may also be extended if you ask us to inform you about future job opportunities.

If your application is successful personal data provided to us in the recruitment process may be further processed by Silver Lake and retained as described in any applicable employee privacy notice.

Your Rights and Choices

Prospects applying for a position with Silver Lake in the UK may have the following rights in relation to that personal data:

  • To request confirmation of whether we process personal data relating to you and, if so, to request a copy of that personal data;
  • To request that we rectify or update your personal data that is inaccurate, incomplete, or outdated;
  • To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
  • Where you have given Silver Lake consent to process your personal data, to withdraw your consent;
  • To request that we provide a copy of your personal data to you or a third party in a structured, commonly used and machine-readable format in certain circumstances;
  • To object to certain of our data processing, such as for direct marketing purposes; and
  • To lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the UK).

If you wish to exercise any of your data protection rights, or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal data you provide us through the Site, you can write to us at Privacy Matters, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025, or at Broadbent House, 65 Grosvenor Street, London W1K3JH, United Kingdom, or e-mail us at [email protected].