Supplemental Privacy Notice

This notice supplements the Baringa Privacy Policy and explains how personal data submitted through the Women in Financial Crime Network Mentoring Programme (“the Programme”) application process will be used.

Who is responsible for your personal data?

Baringa Partners LLP ("Baringa", "we", "us" or "our") is the controller for the purposes of the personal data collected through the Programme application process.

About the Programme

The Programme aims to connect senior financial crime professionals (“Mentors”) with emerging talent in the field (“Mentees”) through structured mentoring relationships. The Programme is designed to support professional development, share financial crime expertise and help the Mentees progress towards their career goals.

Mentors are asked about the areas in which they can offer support, their financial crime expertise and their capacity to support Mentees. Mentees are asked about the areas in which they would value support, the financial crime expertise they are seeking and their career goals. Both Mentors and Mentees may also share optional matching considerations. We use this information to create suitable Mentor-Mentee pairings.

What personal data do we collect?

Depending on whether you apply as a Mentor or Mentee, we may collect:

(a) Name

(b) Email address

(c) Organisation

(d) Job title

(e) Professional seniority level

(f) Whether you wish to participate as a Mentor or Mentee

(g) Areas of expertise, mentoring interests and areas where support is sought

(h) Career goals and development interests

(i) Capacity and availability information

(j) Optional matching preferences and considerations

(k) Any information you choose to include in free-text responses.

Fields marked as required on the application form are necessary for us to assess and match your application. If you do not provide this information, we may be unable to consider your application. All other fields, including matching preferences and free-text responses, are optional.

We do not ask for special category personal data (such as information about your health, ethnicity, religion, political opinions or trade union membership). Please do not include this type of information in any optional or free-text responses.

How do we use your personal data?

We use your personal data to:

• Assess applications to participate in the Programme;
• Match Mentors and Mentees;
• Communicate with applicants regarding their application;
• Introduce matched participants;
• Administer and manage the Programme;
• Monitor participation and the Programme; and
• Respond to enquiries relating to the Programme.

Lawful basis

We process your personal data because it is necessary for our legitimate interests in operating, administering and improving the Programme and facilitating professional mentoring relationships. We have assessed these interests and concluded that the processing is proportionate and does not override your rights and freedoms.

Who receives your information?

Access to application data will be limited to the Programme organising team.

Where a match is made, we will share limited information with your matched Mentor or Mentee, including:

• Name
• Email address
• Organisation
• Professional role or job title

We will not sell your personal data or share it with third parties for marketing purposes.

Use of AI-assisted matching

Baringa may use approved artificial intelligence tools to help identify potential Mentor-Mentee matches from application responses. These tools are provided by approved service providers acting on our behalf and subject to appropriate contractual and security safeguards, including those described under “International transfers”. Any AI-generated suggestions will be reviewed by members of the organising team within Baringa, who may accept, amend or reject them, before a match is finalised or communicated. There will be no solely automated decisions made regarding your participation in the programme. If you would prefer your application not to be considered using AI-assisted matching, you may object by contacting us and your application will be matched manually.

International transfers

Your personal data may be transferred to, or accessed from, countries outside the UK or the European Economic Area (“EEA”). This may occur where our IT and service providers (such as Microsoft, which hosts the application form and our systems) process data on our behalf, or where your matched Mentor or Mentee is located outside the UK or EEA.

Where we transfer personal data to service providers outside the UK or EEA, we will ensure it is protected by relying on adequacy regulations or decisions covering the destination country or, where these do not apply, appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or the EU Standard Contractual Clauses, as applicable.

Where your matched Mentor or Mentee is located outside the UK or EEA, we will share only the limited information described under “Who receives your information?”, and only to the extent necessary to make the mentoring introduction you have applied for.

Retention  

For successful applicants, personal data will generally be retained for the duration of the Programme and for a period of six months afterwards to manage programme administration and respond to any follow-up enquiries.

For unsuccessful or unmatched applicants, application data will generally be deleted approximately three months after the matching cycle closes, unless you separately agree to be considered for a future mentoring cycle

Your rights

You have data protection rights under applicable law, including rights to request access to your personal data, rectification, erasure, restriction of processing, objection to processing and, where applicable, data portability.

Further information about these rights and how Baringa processes personal data is available in the main Baringa Privacy Policy.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection, at ico.org.uk or by calling 0303 123 1113. If you are in the EEA, you may also complain to the data protection supervisory authority in your country of residence, place of work or where an alleged infringement took place. We would, however, appreciate the opportunity to address your concerns before you approach a supervisory authority, so please contact us in the first instance.

Contact us

If you have any questions about how your personal data is used in connection with this programme, please contact: privacy@baringa.com