Lombard Odier takes the private nature of applications and any related personal data very seriously. This Group Candidate Privacy Notice describes how the entities of the Lombard Odier Group handle and protect personal data in connection with recruitment processes.

1. Background

The entities of the Lombard Odier Group (hereinafter referred to as “Lombard Odier” or “the Lombard Odier entity(ies)”) are committed to protecting the privacy and security of candidates’ and any related person’s personal data. A “related person” is an individual whose personal data is provided by the candidate to an entity of the Lombard Odier Group as part of its recruitment process (e.g. a referee, a former employee…). If you transmit information about a related person, you are required to transmit this notice to him/her beforehand.

The Lombard Odier Group has issued a General Group Privacy Notice. This Group Candidate Privacy Notice supplements the General Group Privacy Notice and provides candidates with more detailed information about the personal data Lombard Odier entities may collect, store and process as part of their recruitment process. Upon the effective date of an employment agreement, the Lombard Odier Group Employee Privacy Policy applies.

A reference to “you” or “your” in this Group Candidate Privacy Notice is a reference to the candidate and/or the related person. A reference to “we”, “our” and “us” is a reference to the Lombard Odier entity acting as data controller as part of the recruitment process.

2. Which categories of your personal data do we collect, store and process?

Personal data means any data that identifies the candidate or the related person or that allows, together with other information, for the identification of this person. Much of the personal data we hold and process as part of the recruitment process is provided by the candidate, a related person or an entity appointed to perform background checks in the conditions laid down in annex 1 to this Group Candidate Privacy Notice (to the extent permitted under applicable law). Some data may also come from publicly available sources.

The categories of personal data we collect, store and process includes, but is not limited to the following:

• Your identification information including name, address, phone numbers, e-mail addresses.
• Your previous experiences information and employment history including employers, employment period, employment certificates, reference letters.
• Your qualifications and certifications information.
• The correspondence between you and HR.
• Interview related information.
• Information for checking your backgrounds as described in Annex 1 to this Group Candidate Privacy Notice.
• Information needed for your onboarding including personal account numbers, social security number, pension fund number.
• Cookie information as described in our Cookie notice.

In rare cases, where necessary for the purpose of complying with our regulatory or legal obligations, notably in the field of employment, social security and social protection law, and in so far as it is authorized or required under local law, we may process special categories of personal information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data or sexual orientation.

3. For what reasons do we collect, store and process your personal data?
   • Steps prior to the establishment of a contractual employment relationship

We collect, store and process personal data principally to:

• Review and assess your application;
• Contact you and conduct interviews; and
• Manage your onboarding as a Lombard Odier employee.

• Compliance with legal obligations, to which Lombard Odier is subject

We collect, store and process personal data principally to comply with our obligations as an employer in the private banking and asset management industry (e.g. compliance obligations, conduct background checks…).

• Legitimate interests and protection of our legal position in the event of legal proceedings

We collect, store and process personal data principally for the pursuit of our legitimate interest (to ensure physical security in our premises, to ensure diversity, for analytical purposes…) and to defend our interests in case of civil, administrative, criminal or regulatory requests and litigations.

• Consent

In specific cases, the processing of your personal data will be subject to your consent. In this case we will contact you and seek your consent in due course.

4. How long will we store your personal data?

We store or process your personal data no longer than is necessary for the purposes for which the personal data were collected and processed. In most cases, we delete candidate’s personal data once a year if the candidate’s account has been inactive for at least 12 months on the deletion date.

5. To whom may we transfer your personal data?

The hiring Lombard Odier entity may transfer candidate’s and related person’s personal data to other Lombard Odier entities to which HR functions have be outsourced.

The Lombard Odier Group also uses the platform “Workday” to manage the recruitment process. Such platform is provided by Workday Ltd, an Irish entity using sub-contractors that might process candidate’s and related person’s personal data in the United States of America. With respect to this transfer, we will ensure that Workday Ltd has implemented and maintains appropriate safeguards to ensure the privacy of your personal data.

Furthermore, your personal data may be sent to authorities, previous employers and/or other third parties to confirm or clarify details of the candidate's background, regardless of whether such employers and third parties are based in the relevant jurisdiction or abroad.

6. What rights do you have in respect to of the processing of your personal data?

As a data subject, you have certain rights in respect of the personal data that we process. These rights are described in the General Group Privacy Notice.

7. Data Protection Officer

Should you have any questions relating to this Group Candidate Privacy Notice or want to exercise your rights in respect of the processing described herein, please contact the Lombard Odier Group-Data Protection Officer:

Bank Lombard Odier & Co Ltd

Group Data Protection Officer

11, Rue de la Corraterie

1204 Geneva

Switzerland

E-Mail: [group-dataprotection@lombardodier.com]

 

Appendix 1

1. To the extent permitted under applicable law, before recruiting any new staff, the Lombard Odier entities may follow a standard procedure for checking candidates' backgrounds.

2. As part of this procedure, Lombard Odier may carry out some or all of the following checks:

1. Check the candidate’s identity by obtaining a copy of their ID card or passport;
2. Check the candidate's current place of residence and places where they have lived in the past years by obtaining the requisite supporting evidence;
3. Check the candidate's right to work in the relevant jurisdiction by obtaining a copy of their work permit, where applicable;
4. Check the candidate's academic qualifications by obtaining a copy of documents showing their highest academic qualification;
5. Check professional experience – job title, date of start and end of contract, employment rate, type of contract, reason for leaving, any disciplinary action or other important information related to hiring the candidate – with the most recent employers specifically by taking up references;
6. Check the candidate's criminal record;
7. Check whether the candidate is a Politically Exposed Person (PEP) or on the sanction, watch or blacklists;
8. Check the candidate's financial probity and solvency by obtaining an excerpt from local debt collection and bankruptcy office and consulting information available on specialist databases;
9. Check specialist databases to see, notably, whether the candidate has any conflicts of interest or directorships. 

3. For your information, these checks may be repeated at regular intervals for Lombard Odier staff.

4. Candidates are also informed that some background checks are conducted by subcontractors located in the EEA, Switzerland or the United Kingdom on behalf of Lombard Odier. Subcontractors have given contractual undertakings to Lombard Odier that any information to which they may have access while carrying out background checks on candidates will be treated as strictly confidential and in accordance with applicable data protection legislation.

5. All questions relating to the procedure for background checks should be addressed to the member of Human Resources in charge of your recruitment process.

 

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Política de Privacidade do Grupo Lombard Odier para Candidatos