Privacy Notice for UK Applicants

Effective: 2023 December 1

Westfield Specialty Management Services Ltd., its subsidiaries and affiliates ("Westfield Specialty Ltd" or "we”, "us" or "our") respect your privacy. This Privacy Notice ("Privacy Notice") applies to Westfield Specialty and specifically to the personal data of job applicants of Westfield Specialty Ltd.

This Privacy Notice explains Westfield Specialty Ltd’s practices regarding personal data, including the kinds of personal data we may collect and how we intend to use and share that personal data.

1. Personal Data We Collect

Westfield Specialty Ltd collects personal data from job applicants ("Applicant Personal Data"). The personal data we collect may include without limitation:

Contact Information: name, address, phone number, email address;
Identification Information: date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number; and
Education and Work History Information: employment history, education, professional qualifications, information that may be recorded on a resume/CV or application form, language abilities.

Where Westfield Specialty Ltd is required to make reasonable workplace adjustments based on applicant characteristics, we may also process certain health data of applicants (“Special Category Personal Data”).

Where Westfield Specialty Ltd carries out background checks and risk assessments on applicants this may involve the processing of criminal record data and this will only be processed where such processing is specifically authorized or required by law (“Data Concerning Criminal Convictions and Offences” and collectively with Special Category Personal Data “Sensitive Personal Data”).

Sources of Applicant Personal Data

We may collect Applicant Personal Data directly from applicants or from third parties, such as recruitment agencies, referees, background check providers, your former employer, medical professionals, disclosure and barring services, HMRC, any LinkedIn account that may be maintained by the applicant, and information from publicly available sources.

Failure to Provide Applicant Personal Data

If you fail to provide Applicant Personal Data when requested, we may not be able to: (i) process your application successfully; or (ii) comply with applicable legal obligations.

2. Purposes and Legal Bases Of Your Applicant Personal Data

We process Applicant Personal Data for the following purposes, depending on the nature of the personal data and the relationship we have with you:

Category of Personal Data	Purpose of Processing	Legal Basis
All categories of Applicant Personal Data	Maintaining records regarding the recruitment process	Westfield Specialty Ltd has a legal obligation to do so (Article 6(1)(c), UK GDPR) including to comply with employment and immigration laws Westfield Specialty Ltd has a legitimate interest to ensure that we maintain accurate and comprehensive records (Article 6(1)(f), UK GDPR)
Contact Information, Identification Information, Education and Work History Information	Making a decision about your recruitment and appointment, including the right to work	Westfield Specialty Ltd must be able to manage and perform contracts with you (Article 6(1)(b), UK GDPR) Westfield Specialty Ltd has a legal obligation to do so (Article 6(1)(c), UK GDPR) including to comply with employment and immigration laws Westfield Specialty Ltd has a legitimate interest in effectively managing the appointment of applicants (Article 6(1)(f), UK GDPR)
Identification Information, Contact Information	Communicating with the applicant, recruitment agents and other vendors and business associates involved in the recruitment process	Westfield Specialty Ltd has a legal obligation to do so (Article 6(1)(c), UK GDPR) Westfield Specialty Ltd has a legitimate interest to conduct the recruitment process (Article 6(1)(f), UK GDPR)
All categories of Applicant Personal Data	Entering into or performing the contract entered into with you	Westfield Specialty Ltd must be able to manage and perform contracts with you (Article 6(1)(b), UK GDPR) Westfield Specialty Ltd has a legal obligation to do so (Article 6(1)(c), UK GDPR) including to comply with employment and immigration laws
All categories of Applicant Personal Data	Preparing for and acting in relation to inquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation	Westfield Specialty Ltd has a legitimate interest to manage its business and to ensure that all investigations and proceedings are managed efficiently and effectively (Article 6(1)(f), UK GDPR) Westfield Specialty Ltd may have a legal obligation to do so (Article 6(1)(c), UK GDPR)
Identification Information, Contact Information, Education and Work History Information	If Westfield Specialty Ltd is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, then Applicant Personal Data may be transferred as part of such a transaction	Westfield Specialty Ltd has a legitimate interest to manage its business (Article 6(1)(f), UK GDPR)
Sensitive Personal Data
Data Concerning Criminal Convictions and Offences	Westfield Specialty Ltd may process Applicant Personal Data relating to criminal convictions and offences to determine whether applicants should be offered a role with the organization	Westfield Specialty Ltd may have a legitimate interest to determine whether an applicant is suitable for a particular role in the organisation (Article 6(1)(f) and 10, GDPR); Section 10 Schedule 1 Part 2 paragraph(12), UK Data Protection Act 2018)
Special Category Personal Data	Westfield Specialty Ltd may process Special Category Personal Data to monitor demographic information to achieve diversity goals	Westfield Specialty Ltd may have a legitimate interest to monitor the demographic make-up of the organisation (Article 6(1)(f) GDPR and Article 9(2)(g) GDPR); Schedule 1 Part 2 paragraph(8), UK Data Protection Act 2018)

You have a right to object to the processing of your Applicant Personal Data where that processing is carried out for Westfield Specialty Ltd’s legitimate interests. Please note however that Westfield Specialty Ltd may not be able to fulfil this request in all instances.

3. Disclosure of Applicant Personal Data

We may share Applicant Personal Data to the extent necessary for the above purposes with the following recipients:

Vendors and Service Providers

We may engage third parties to perform certain functions on our behalf. To do so, we may disclose Applicant Personal Data to our third-party vendors and service providers such as, onboarding & new hire management, background checks, talent acquisition & staffing and information technology systems providers.

Affiliates and Subsidiaries

Westfield Specialty Ltd may share Applicant Personal Data with our affiliates, including those in the U.S., and subsidiaries for our and our affiliates’ and subsidiaries’ internal business purposes.

Governmental Authorities

We may disclose your Applicant Personal Data to local tax authorities and any governmental or administrative body where we determine that it is necessary or desirable in order to comply with applicable laws, court orders, or government regulations or to protect the rights or property of Westfield Specialty Ltd or any of its applicants.

Merger, Sale or other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, then your Applicant Personal Data may be transferred as part of such a transaction as permitted by law and/or contract.

Other Third Parties

Independent public accountants and auditors, authorized representatives of internal control functions such as, audit, legal and/or corporate security and Lloyds of London.

4. Your Individual Rights

In accordance with applicable law, you may have the right to: (i) request access to or a copy of your Applicant Personal Data; (ii) receive an electronic copy of your Applicant Personal Data that you have provided to us, or ask us to send that data to another organization in a machine-readable format (known as the “right of data portability”); (iii) request that we restrict our uses of your Applicant Personal Data; (iv) request correction of inaccurate, untrue or incomplete Applicant Personal Data; (v) object to the processing of Applicant Personal Data in certain circumstances; and (vi) request erasure of your Applicant Personal Data subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request – unless we are entitled to extend this period in which case we will inform you of this extension. To protect your privacy, Westfield Specialty Ltd may take steps to verify your identity before fulfilling your request.

You also have the right to lodge a complaint with the applicable supervisory authority if you believe our processing of your Applicant Personal Data violates applicable law.

It is important that the Applicant Personal Data we hold about you is accurate and current. Please keep us informed if your Applicant Personal Data changes during the recruitment process with us.

Click Data Subject Rights Request, or contact a member of the Privacy Office by email or post, per the addresses below, to submit a request relevant to your rights.

5. Data Retention

We will retain Applicant Personal Data collected from applicants who are not offered employment with Westfield Specialty Ltd for up to 1 year or in case of a legal or regulatory obligation requiring us to retain specific records for a set period of time, for that period of time.

6. Security of Your Applicant Personal Data

We implement reasonable technical and organizational security measures designed to secure and protect Applicant Personal Data. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Applicant Personal Data.

7. International Transfers of Applicant Personal Data

We may disclose Applicant Personal Data for the above listed purposes to recipients located in countries outside of the UK, including the U.S., some of which may not have data protection laws equivalent to those in the UK.

For intra-group transfers of Applicant Personal Data, Westfield Specialty Ltd has entered into an intra-group data transfer agreement from Westfield Specialty Ltd to Ohio Farmers Insurance Company (“OFIC”) entities outside the UK/EEA/Switzerland or otherwise when we rely on a derogation for the international transfer of Applicant Personal Data (e.g., where the transfer is necessary for the defence of legal claims). The identity and contact details of OFIC are set out in this section and below. The categories of Applicant Personal Data processed by OFIC are set out above. OFIC may also transfer Applicant Personal Data to the third party recipients who may be located outside the UK/EEA/Switzerland for the purposes set out herein. OFIC will only make such onward transfers to recipients ensuring appropriate safeguards in compliance with applicable law, or where otherwise permitted by the SCCs and which may include entry into SCCs.

For cross-border transfers of Applicant Personal Data to other recipients, including our service providers, Westfield Specialty Ltd will put in place appropriate safeguards so that Applicant Personal Data is and remains protected. These may include implementing the Standard Contractual Clauses with the UK International Data Transfer Addendum or Binding Corporate Rules or otherwise when we rely on a derogation for the international transfer of Applicant Personal Data (e.g., where the transfer is necessary for the defence of legal claims).

You may obtain further information and a copy of the relevant data transfer mechanisms that we have in place via contacting privacy@westfieldgrp.com.

8. Changes to This Privacy Notice

This Privacy Notice is reviewed and updated periodically. The most recent version of the Privacy Notice is reflected by the version date located at the top of this page. We encourage you to review this Privacy Notice often to stay informed of how we may process your information. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law.

9. Contact Us

For the purposes of UK data protection law, the entity which manages the hiring process where you are an applicant (Westfield Specialty Management Services, Ltd.) is the controller of personal data.

If you have any question about this Privacy Notice or the practices described in it, or would like to contact us about any rights you may have with regard to your personal data, you can contact us via the Data Subject Rights Request above, email, or postal mail as follows:

Email: privacy@westfieldgrp.com.

Post:
Floor 36
22 Bishopsgate
London
EC2N 4BQ
United Kingdom