Last updated: 24 August 2022
1. Purpose - Robinhood Markets and Robinhood U.K. Ltd values and respects the privacy of its applicants. This policy describes the privacy practices of Robinhood and its affiliates (collectively, “Robinhood”) in connection with the personal data collected about its applicants, as defined below.
2. Scope - This policy applies to the processing of personal data by Robinhood relating to any individual that applies to work for Robinhood and who is located in the United Kingdom or a Member State of the European Union (“applicants”).
3. Collection of Personal Data - Robinhood collects the following categories of personal data about applicants:
- Identifiers, such as name and contact information (including phone number, email and physical address) and government-issued identification numbers;
- Professional or employment-related information and education information submitted in connection with an application to work for Robinhood (such as employment history, work experience, qualifications, references, referees, professional and academic history);
- Background report information, including education history and history of residential addresses, records of any previous criminal offenses (where applicable and upon your consent as required by law) and processed prior to extending an offer;
- Visual information, such as photographs or video obtained through CCTV cameras when arriving for on-site interviews;
- Financial information (such as banking information) where we need to provide you with reimbursement during the recruitment process;
- Work permit data, including work visa or other information related to work eligibility;
- Inferences drawn related to potential work performance, including abilities and aptitudes;
- Personal data revealing racial or ethnic origin information needed to comply with legal obligations and internal policies relating to diversity and anti-discrimination; and
- Disability information needed to comply with legal obligations.
Robinhood collects the majority of the above information directly from applicants but may also collect information from other sources. For instance, during the recruitment process, Robinhood may request references from third parties (such as applicants’ former employers, colleagues or managers) and carry out screening and vetting processes using third-party sources. We may also collect applicants’ personal data from recruitment agencies if they are applying through one. Robinhood also generates some information from its applicants, such as inferences raised about the applicant’s prospects for employment and notes made during an interview with an applicant. Additionally, personal data may be collected indirectly (for example, building and location access control and CCTV footage may be obtained when applicants visit our offices), if and to the extent permitted by applicable laws.
4. Purposes for Processing - Robinhood processes personal data about applicants for the following lawful purposes:
- as necessary for compliance with a legal obligation, such as to comply with financial and employment regulatory requirements (including to process your identifiers and background check information);
- as necessary in order to take steps at the request of the applicant prior to entering into a contract (including to process your identifiers, professional or employment-related information, and your background check information);
- as necessary in order to protect the vital interests of the applicant or of another natural person, such as an emergency where the health or security of an applicant or other person is in danger during or after an on-site visit (including to process your identifiers); and
- for the following legitimate interests: evaluation of your suitability for the role you are applying for, to communicate with you as needed during the interview process, to evaluate, analyse, and report on the recruitment process, and protection of Robinhood’s network and property (including to process your identifiers, professional or employment-related information and inferences as may be needed).
5. Disclosure of Personal Data - Robinhood shares personal data about its applicants as follows:
- with its affiliates and subsidiaries in facilitating planning and resource allocation, policy development, financial reporting and similar legitimate business interests of the Robinhood family of companies;
- with companies that perform services to Robinhood or to applicants, including recruitment agencies, payment service providers, and pre-screening check providers;
- as part of, or during negotiations of, any merger or sale of Robinhood assets;
- with regulatory authorities or other third parties where Robinhood believes disclosure is required by applicable law and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
- with law enforcement authorities as necessary to protect Robinhood’s corporate assets from theft, fraud or damage; and
6. Personnel Rights - Subject to certain limitations and exceptions, personnel have a number of legal rights regarding Robinhood’s processing of personal data that relates to them, as further described below.
- A right of access: applicants have the right to request access to, or a copy of, the personal data Robinhood processes about them (subject to some limited exceptions which may mean we may not be able to provide the applicant with all the personal data that we process).
- A right of rectification: applicants have the right to request that Robinhood correct or supplement inaccurate or incomplete personal data it processes about them.
- A right of erasure: applicants have the right to request that Robinhood delete personal data in certain contexts (such as where the data is no longer necessary in relation to the purposes for which it was collected).
- A right to restriction of processing: applicants have the right to request that Robinhood restrict processing of personal data in certain cases (such as if Robinhood no longer needs to process the data for its purposes, but the data subject requires the data for legal claims), so that Robinhood can store such data, but not further process it.
- A right to data portability: in certain cases (such as where processing is based on performance of contract and is undertaken with automated means), applicants have the right to request personal data they have provided to Robinhood to be delivered to them in a structured, commonly used and machine-readable format, so that the they can transmit such data to another controller without hindrance from Robinhood.
- A right to object to processing: applicants have the right to request that Robinhood stop processing personal data in certain contexts (such as if objecting to a specific processing activity undertaken in Robinhood’s legitimate interests unless Robinhood has compelling legitimate grounds for the processing that override the applicant’s concerns).
- A right to revoke consent: When processing is based on consent, applicants have the right to revoke such consent at any time.
- The right to file a complaint: applicants have the right to file a complaint regarding Robinhood’s data protection practices with the relevant supervisory authority. If you are in the UK, please see the ICO contact information at: https://ico.org.uk/global/contact-us/. If you are in the EEA, please see this directory: https://edpb.europa.eu/about-edpb/board/members_en.
7. Retention of Personal Data - Robinhood will erase or render anonymous personal data when the processing is no longer necessary, and applicable law no longer requires Robinhood to retain it. We are required to retain data for six months from the hiring decision.
8. Cross-Border Transfer of Personal Data - Robinhood transfers personal data originating from the UK and EEA to the United States and other countries, which may not provide equivalent levels of data protection as the originating jurisdiction. Any transfer of this data to a country which the UK or the European Commission (as applicable) does not recognize as having an adequate level of protection will be conducted pursuant to the standard contractual clauses entered into by the Robinhood group, a copy of which may be made available upon request.
9. Contact Details - applicants may contact Robinhood UK (which serves as the representative of other Robinhood affiliates) with questions or complaints at email@example.com
10. Data Controller - Robinhood is the controller of your personal data.