Privacy Policy for Applicants

Privacy Policy for Applicants

Policy Statement


TorFX takes data privacy very seriously and recognises the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.

To consider your application for a job at TorFX we need to collect information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.

Please read this notice carefully. Here we set out the basis on which any information we collect about you or from you, or that you provide to us, will be processed by us and other parties in connection with your application. TorFX (“our”, “us” and “we”) commits to using your information only in accordance with the terms of this Privacy Policy.

For the purposes of this Privacy Policy, the term “information” means any confidential and/or personal data or other information related to your application for a role at TorFX.

By visiting this website or providing your personal information to one of our employees, for example by telephone or email, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

This includes consenting to the processing of any sensitive personal information you provide, as described below in Section 2.

If you have concerns about any of the terms of this Privacy Policy, please call us so that we can provide further information.

1. Data we collect about you

TorFX collects personal data directly from you. For example, it collects personal data when you:

  • deal with TorFX in person, by telephone, letter, fax, email or via our website;
  • supply a CV or application form; and
  • submit any other information in connection with your application.

If we progress your application we may ask for additional information from you such as your date of birth, a copy of your passport, proof of address, your nationality, evidence of right to work in the UK, for example a copy of your work visa, and your bank account and sort code. These may be required to verify your identity, meet regulations obliging us to verify your right to work or to sponsor you for a work visa and so we can arrange to pay your salary.

Personal data about you may also be collected from third parties that TorFX contacts for verification or vetting purposes. For example when TorFX receives:

  • any reference about you;
  • results of enquiries of former employers, work colleagues, professional associations, educational establishments or registration bodies;
  • the results of any psychometric, competency or medical test;
  • performance feedback (whether positive or negative);
  • any complaint from or about you in the workplace;
  • any information about a workplace accident in which you are involved;
  • any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved.

TorFX will normally require you to provide signed consent to enable us to obtain personal data from third parties (unless you have indicated your consent in some other way) but, if TorFX does not have your prior consent, it will take reasonable steps to inform you as soon as possible that it has collected personal data from a third party and ensure you are aware of the purposes for which we have collected your personal data.

We may also ask you to sign documents, such as your contract, using an online document service and thereby collect your digital signature.

2. How TorFX uses and discloses your personal data

When you apply for a job at TorFX, we will use the personal data you supply to assess your suitability for roles that we may have available and to answer your enquiries or questions. As part of this process we will share your details internally within TorFX with those hiring managers who may have a need for someone with your skills.

TorFX may also disclose your personal data to third parties if they have a proper interest in the disclosure, such as:

  • external vetting bodies e.g. to obtain DBS checks;
  • third parties who perform functions on TorFX’s behalf and who also provide services to TorFX, such as professional advisors, IT consultants carrying out testing and development work on TorFX business technology systems;
  • a professional association or registration body or regulatory or law enforcement agencies if TorFX is required by law to do so.

3. To support our business and provide services to you

TorFX works with third-party service providers, including business partners under contract with us who support our business operations, such as HR services and technology services. We need to disclose user data to them from time to time so that the services can be performed. Our contracts with our business partners dictate that they only use your information in connection with the services they perform for us and not for their own benefit.

By accepting this Privacy Policy and applying for a role at TorFX, you expressly consent to the transfer of your data to those third parties for the purposes listed.

4. Mergers and acquisitions

As with any business, it is possible that in the future TorFX could buy, merge with, or be acquired by, another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If TorFX or a substantial proportion of its assets are acquired by a third party, information held by us about applicants will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

Unless required or permitted to do so by law, TorFX will not otherwise share, sell or distribute any of your personal data without your consent.

5. Consequences of not providing personal information

If you do not give TorFX the personal data we request (provided that the data requested is reasonable and relevant to the services being provided to or for you), we will be unable to progress your application for a role with TorFX.

6. Systems Security Policy

TorFX has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only authorised employees of TorFX and our business partners processing data on our behalf have access to your personal data. All TorFX employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by TorFX to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. Contracts with business partners acting as data processors for TorFX involving personal data require an adequate level of security and require that personal data is processed only as instructed by TorFX.

7. Data Retention Policy

We normally retain CVs, interview notes and other communications for 6 years to ensure fair treatment of all applicants. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

8. Transferring data overseas

TorFX is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.

The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the processing of your application and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries).

Each time you apply for a role at TorFX, we may transfer your relevant information to the service providers as described above. By submitting your information you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

TorFX and/or the third parties to whom we may disclose your personal data may store your personal data on a server overseas. By providing personal data you agree your data may be transferred to servers located overseas.

9. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and to provide interest-based advertising. You may adjust the settings on your browser to refuse cookies but some of the services on our website may not work if you do so. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

10. Third party websites

Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates. Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.

11. You have the following rights:

To ask us to correct any information we hold about you if it is incorrect.

Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. You can correct your details by writing to us at any time.

To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.

Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.

To ask us to return to you information you provided to us, also known as ‘data portability’.

You can ask us to send you in electronic format the information you provided to us under our Terms and Conditions or under consent.

To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.

If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.

To ask not to be subjected to automated decision making and profiling.

TorFX does not make any hiring decisions based solely on automated decision making. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.

To ask for a copy of the information we hold about you.

We will endeavour to respond to your request within 30 days, however at times of high demand we may need 90 days to compile a full response.

To ask us not to process your information for marketing purposes.

We will not use your application details to contact you for marketing purposes.

You may exercise any of the above rights by contacting us at dataprotection@torfx.com.

12. Contacting us

The Data Controller

The Data Controller is Tor Currency Exchange Limited, Registered office address PZ360, St Mary’s Terrace, Penzance, Cornwall, TR18 4DZ, Company number 5193147.

Contacting us with questions or requests

If you want to exercise your right to access your information or have any questions about this Privacy Policy, TorFX’s information practices, or your dealings with TorFX, you can contact us by writing to us at the address above.

Complaints to the Data Protection Officer

If you believe that we have breached a privacy law with which we should comply, please send an email to dataprotection@torfx.com. We aim to respond in a reasonable time, normally within 30 days. Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.

Complaints to the UK Information Commissioner

You have the right to complain to the UK Information Commissioner's Office if you believe we have not handled your request in an appropriate manner. For information on contacting the UK Information Commissioner please see their website.

13. Changes to this Privacy Policy

We may amend this Privacy Policy at any time. Any changes we may make will be posted on the TorFX website, so please check back frequently.

Your continued use of our website(s) after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, you may withdraw your application at any time.