Candidate Privacy Notice

Thank you for your interest in joining Circle!

1. What is the purpose of this privacy notice?

You have been directed to or provided with a copy of this privacy notice because you are applying to join us as either an employee, worker or contractor.

We have set out in this privacy notice how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It also provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

Please read this privacy notice carefully before you submit your application (and other related documents) to us. By submitting your application to us or continuing with the application process, you agree that you have read and understood this privacy notice.

2. Data controller, data protection officer and other important information

Circle is made up of different legal entities. This privacy notice is issued on behalf of the Circle Group so when we mention “Circle”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Circle Group responsible for processing your data.

Data controller: A data controller is the entity responsible for deciding how it holds and uses your personal information.

Circle UK Trading Limited
If you are applying for a role in Europe other than the Republic of Ireland, then Circle UK Trading Limited is the data controller of your personal information and its contact details are set out below:

Postal address: TOG 81 Rivington Street, London EC2A 3AY, United Kingdom

Circle Internet Financial Trading Company Limited
If you are applying for a role in the Republic of Ireland, then Circle Internet Financial Trading Company Limited is the data controller of your personal information and its contact details are set out below:

Postal address: 4A Prince’s Street South, Dublin 2

Data protection officer: We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact your recruitment point of contact (“POC”) in the first instance, our recruitment team will work with our data protection officer to address your queries and/or concerns.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (www.ico.org.uk), the UK supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns first before you approach the ICO.

3. The kind of information we hold about you

In connection with your application, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and cover letter.
  • The information you have provided on our application form, including name, title, telephone number, personal email address, your website or Linkedin profile.
  • Any information you provide to us during an interview.
  • We may also collect, store and use the following “special categories” of more sensitive personal information: Information about criminal convictions and offences.

4. How is your personal information collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • A person who recommended you for the role from whom we collect the following categories of data: information contained in your curriculum vitae and cover letter, employment history, qualifications, gender.
  • Recruitment agencies, from which we collect the following categories of data: information contained in your curriculum vitae and cover letter.
  • Background check provider, from which we collect the following categories of data: criminal convictions or offences, civil judgements or orders, credit related information.
  • Your named referees.
  • Publicly accessible sources including information on your Linkedin profile and any information about you which is publically available through internet searches.
  • Your Circle account (if you have one), from which we collect the following categories of data: your transaction history in particular whether it has been previously suspended or closed due to fraud or misuse of your Circle account.

5. 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.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you for the relevant role since it would be beneficial to our business to appoint a suitable candidate to the role.

We also need to process your personal information to decide whether to enter into a contract of employment or other type of contractual arrangement with you.

Having received your CV, cover letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview or a series of interviews. We will use the information you provide to us at the interviews to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and carry out background checks.

If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a background check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

6. How we use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

7. Information about criminal convictions

We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to 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 the role. Given that Circle is a regulated entity in the financial services industry, which requires a high degree of trust and integrity, we will seek a basic, standard or enhanced disclosure of your criminal records history as we consider appropriate for your role.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

8. Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

9. Data sharing

Why might you share my personal information with third parties?
We will only share your personal information with the following category of third parties for the purposes of processing your application: recruitment agencies, search consultancies, background check providers and other entities within the Circle group of companies. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. International transfers

When we share your personal data within the Circle group of companies, it may involve transferring your data outside the European Economic Area (EEA) to the US. We (including our group companies that may handle your information) comply with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Some third party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

11. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. Data retention

How long will you use my information for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For further details of retention periods for different aspects of your personal data please contact your POC.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. Rights of access, correction, erasure, and restriction

Your rights in connection with personal information
Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). Please note: your right of erasure may not apply for various reasons including if we need to retain your personal information in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of erasure, we will let you at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your recruitment POC in writing.

14. Right to withdraw consent

When you applied for a role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact your recruitment POC. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

15. No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

16. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.