Candidate privacy policy

Nucleus will collect and process personal data in line with our legal and regulatory obligations for the purposes of recruitment and selection.  As a “data controller”, this privacy notice describes how we collect and use personal and special category information about you during the recruitment process.

Who we are

This privacy policy applies to James Hay Partnership Management Limited and Nucleus Financial Group Limited (“we”, “our”, “us” or “Nucleus”).

What information we use and collect

We will only use your personal information when the law allows us to, and this will be:

•    Where we need to comply with a legal, contractual, or regulatory obligation.
•    Where you provide consent to the processing for the purposes of this application

How is your personal information collected?

As part of the application process, we will ask you to complete an application form as well as uploading your CV to our recruitment system. The information we will ask you for includes:

•    Personal details such as name, title, address, telephone numbers, personal email address.
•    Recruitment information, such as copies of right to work documentation, and other information included in a CV or the application form as part of the application process.

We may also receive information about you from other third parties, including recruitment agencies. Applicants can contact a member of the people team for detail on who has provided this data to us.

We’re dedicated to Nucleus being an inclusive and diverse place to work, and to help us in our recruitment efforts, we may also collect, store and use “special categories” of personal information. It’s important that we gather this information to help us see trends and patterns, enabling us to make any changes to our recruitment approach as needed.

The type of information we may ask for includes:

•    Gender
•    Level of education
•    Religion
•    Ethnicity
•    Age (range)
•    Sexual orientation
•    Disability

While we ask you to provide this information, it’s not mandatory and there is an option to opt out. Your information will not be used in the screening and selection for interview process.

Any answers given will be anonymised at the point of collection, treated confidentially and only aggregated data is shared with the people team. Where trends emerge, this will be shared with the business, but on an anonymised basis.

Information about criminal convictions

We envisage that we will process information about criminal convictions.  We will collect information about any criminal convictions you may have 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 record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

•    Certain roles require a high degree of trust and integrity since they involve dealing with for example, high value investor money, vulnerable investors, and investor data and so we would like to ask you to seek a basic disclosure of your criminal records history.
•    In addition, we have a duty of care to our existing staff population and must at all times endeavour to meet this.

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

How will we use information about you?

We will use any information you provide in the following ways:

•    For selection criteria for roles you have applied for, and to move your application through the various stages of the recruitment process, including interview and offer of employment.
•    To review and monitor who and where the applications are coming from, in line with our commitment to diversity and inclusion. This data will enable us to make changes to our recruitment approach as necessary

Automated decision making

We do not use any automated decision making as part of our recruitment process.  

To ensure our candidates have the best possible experience, however, we filter candidates based on salary expectations and align this to the role we’re recruiting for. Where your salary expectation is over the budget for the role, you will receive an email advising you of this and giving you the opportunity to contact someone in the people team for more information and enabling you to tell us that you’d still like to be considered for the role.


We use a recruitment software provider to manage and track our roles and applications. All candidate information is held within this system and stored in the USA.

Data retention

We will retain your information for 180 days, after which point all personal information will be deleted from our system.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights

You have the right to:

•    Request access to your personal information.
•    Request correction of the personal information that we hold about you.
•    Request erasure of your personal information.
•    Request the restriction of processing of your personal information.
•    Request the transfer of your personal information to another party.
•    Lodge a complaint with the Information Commissioner

You can exercise these rights by contacting In some circumstances, we may refuse your request, for example, we may refuse to delete information if we need to retain it for legal reasons or in order to be able to defend a claim. We will let you know if your request has been refused and explain the reasons to you.