1. INTRODUCTION
Entrepreneurs First Operations Ltd (“EFOL”) and Entrepreneurs First Investment Manager LLP (“EFIM”) (together referred to as “EF”, “we”, “us”, “our”) are committed to protecting the privacy and security of the personal data we collect from employees, consultants, workers, and contractors (“you”, “your”). We are further committed to ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
The purpose of this privacy notice is to explain what personal data we collect about you, how we use it, and your rights during and after your working relationship with us. EFOL is a limited company registered in England and Wales under registration number 09064488, with its registered office at Senna Building, Gorsuch Place, London, E2 8JF. EFIM is a Limited Liability Partnership, registered under company number OC397263, authorised and regulated by the Financial Conduct Authority (FRN 807367), with its registered office at International House, 64 Nile Street, London, N1 7SR.
We are registered with the UK’s supervisory authority, the Information Commissioner’s Office (the “ICO”), for the processing of Personal Data under the following registration numbers: ZA078280 for EFOL and ZA123384 for EFIM
This privacy notice applies to all current and former EF employees, workers, and contractors. It does not form part of any employment contract or contract for services. Please read this notice together with any other privacy notice we may provide when collecting or processing specific personal information about you.
We may update this privacy notice from time to time to reflect changes in applicable laws and our processing practices.
2. PERSONAL DATA WE COLLECT
Personal data refers to any information that identifies or can be used to identify an individual. This does not include anonymous data, where all identifiable information has been removed. We also collect ‘special category personal data’, which is more sensitive and requires a higher level of protection, see the section below for further detail.
We collect and process your personal data as part of our employment relationship. Some of this data is gathered during the recruitment process, and additional data may be obtained from third parties, such as references from previous employers or background screening providers. We continue to collect and generate personal data throughout your time with us, ensuring we only collect data necessary for our business relationship.
Please note that references provided to or by us are confidential. Therefore, you will not receive a copy of references given to or received from others.
The categories of personal data we may collect include:
- Personal contact details, next of kin, and emergency contact information
- Date of birth, gender, marital status, and dependents
- National Insurance number, bank details, payroll records, and tax status
- Start date, salary, place of work, annual leave, pension, and benefits information
- Passport copies and other identification documents
- Employment records, including qualifications, skills, job titles, work history, and training records
- Compensation history, including entitlement to pensions, equity schemes or insurance cover
- Performance, disciplinary, and grievance records
- IT systems usage information
- Health information, including medical history
3. SPECIAL CATEGORY PERSONAL DATA
We may also collect, store, and use special category personal information, which is a more sensitive type of data. This may include details about your physical or mental health or disability status. For example, we might gather information about your health and medical conditions for health and safety purposes, enabling us to make necessary adjustments to your work environment. Additionally, we may request equal opportunities monitoring information, though providing this information is entirely optional.
4. HOW WE COLLECT YOUR PERSONAL DATA
EF collects your personal information in a variety of ways. For example, we would have collected your personal information directly from you as part of the recruitment process and you would have provided this to us via your CV, application form, correspondence and through interviews, meetings or other assessments. We will also continue to collect personal information about you during the course of your employment.
EF may have also collected personal data about you from third parties, such as references supplied by your former employers and pre-employment screening checks, this is only carried out with your consent.
5. PURPOSES AND LAWFUL BASES FOR USING YOUR PERSONAL DATA
We will only use your personal data when the law allows. Most commonly, we will use your personal information in the following circumstances:
- Where it is necessary for the purposes of the employment contract in which we have entered;
- Where we need to comply with a legal obligation;
- Where it is in our legitimate interests (or those of a third party) to do so; and
- We may also use your data in the following situations, which are likely to be infrequent:
- With your consent;
- Where we need to protect your vital interests (or someone else’s); or
- Where it is needed in the public interest.
During and after the end of the employment relationship, we may use your personal data for the following purposes and on the following lawful bases:
| Purpose | Lawful Basis for Processing |
|---|---|
| To manage, administer and maintain our employment relationship, which includes: • paying you, • providing you with employment benefits, • performance reviews, • managing disciplinary and grievance processes, • managing sickness, • determining training and development requirements, and • making decisions about promotions or ending our working relationship. |
We process this personal data in the performance of the contract of employment between us and to fulfil our legal obligations.
It is in our legitimate interests to manage your performance at work and provide personal development and training opportunities. When processing your special category data, we do so under our obligations and responsibilities as your employer. In some circumstances we may also process this data with your explicit consent or in your vital interests if unable to give consent. |
| Emergency health and welfare reporting to emergency services, next of kin and other interested parties, • ensuring your health and safety in the workplace, and • reporting health and safety incidents.We may also process health and welfare data for our own internal purposes such as ensuring your health and safety in the workplace including the monitoring of the health of our employees for the purpose of ensuring our offices are a safe environment to work in. |
It is necessary to meet our legal obligations (to make reasonable adjustments to your workplace) and to protect your vital interest that we process the personal information of both you and your next of kin, in case of emergency.
When processing your special category data, we do so under our obligations and responsibilities as your employer. We may also process your special category data for the purposes of public health. When we do so we ensure that any individual handling this data is bound by a duty of confidentiality. |
| For the purposes of business management and planning, which includes but is not limited to; • accounting and auditing, • product development • dealing with legal disputes involving you or other employees, consultants, workers, and contractors. |
It is in our legitimate interests that we process this personal data to identify areas for improving staff retention, develop new products and services and manage the business. |
| To manage, administer and maintain our employment relationship, which includes; • recruitment and selection campaigns, • maintaining accurate and up to date employment records, contact details, records of employee contractual and statutory rights, • operating and keeping a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace, • operating and keeping a record of employee performance, to plan for career development, and for succession planning and workforce management purposes, • operating and keeping a record of absence and absence management procedures, to allow effective workforce management and ensuring that employees are receiving the pay or other benefits to which they are entitled, • obtaining occupational health advice, to ensure that we comply with our lawful duties under the Equality Act 2010 in relation to individuals with disabilities, meet our obligations under the Health and Safety at Work Act 1974, and ensuring that employees are receiving the pay or other benefits to which they are entitled, • operating and keeping a record of other types of leave to allow effective workforce management, to ensure that we comply with our duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled, • ensuring effective general people tasks and business administration, • providing references on request for current or former employees, • responding to and defending legal claims, and • maintaining and promoting equality in the workplace. |
It is in our legitimate interests before, during, and after the end of the employment relationship, to process this employee data.
We may also process this personal data in the performance of the contract of employment between us and to fulfil our legal obligations. When processing your special category data, we do so under our obligations and responsibilities as your employer. |
Conditions for processing special category personal data
We will only process “special categories” of sensitive personal data when we meet one of the legal conditions required to do so. This includes complying with legal obligations or exercising specific rights in the field of employment law. In rare cases, we may ask for your explicit consent to process such data.
We typically process special category data related to your physical or mental health, or disability status, to ensure workplace health and safety, assess fitness for work, provide necessary adjustments, manage sickness absence, and administer benefits.
6. SHARING YOUR DATA
Internally, your data is shared with the People and Finance teams, your line manager, senior management, and the IT Security team. We only share the information necessary to perform our duties.
Externally, we may share your data with third parties where required by law, to manage your employment, or where we have a legitimate interest, such as sharing data with payroll providers, pension administrators, IT services, emergency services, or healthcare professionals in urgent situations.
All EF third-party service providers with whom we share your personal data are required to take appropriate security measures to protect your personal data 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 and contractual agreement.
7. INTERNATIONAL TRANSFERS
Your personal data may be shared within the EF group. This may include transferring your personal data to the United States, Germany, Singapore, France and India.
We may also share your personal data with third party service providers located in a third country outside the UK where the data protection laws are not equivalent to those within the UK. If we do so, we will enter into either International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) which contractually obligate the entities in those countries to operate to the data protection standards expected within the UK. In such cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the data processing contract between us.
8. HOW WE PROTECT PERSONAL DATA
EF takes the security of your data seriously. We have implemented appropriate technical and organisational measures to safeguard your personal data and protect it from accidental or unlawful destruction, loss or alteration and from unauthorised disclosure or access.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data.
9. HOW LONG WE KEEP YOUR DATA
We only retain your personal data for as long as is necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Details of retention periods applicable to employee, consultant and contractor personal data are set out in our Data Retention & Destruction Policy and Schedule.
10. DATA SUBJECT RIGHTS
You have several rights regarding your personal data, including:
- Right to be informed: You are entitled to know what personal data we collect, how it is used, the lawful basis for processing, who it is shared with, and how long it will be retained. Our privacy notice provides this information.
- Right of access: You can request a copy of the personal data we hold about you.
- Right to rectification: If any of the information we hold is inaccurate or incomplete, you have the right to request corrections.
- Right to erasure (‘right to be forgotten’): You can request the deletion of your personal data in certain circumstances.
- Right to object: You can object to us processing your personal data, especially for marketing purposes.
- Right to restrict processing: You can request that we limit how we use your personal data.
- Right to data portability: You can ask us to transfer your personal data to another organisation.
- Automated decision-making: You have the right to object to decisions made solely through automated processing that significantly affect you. We do not currently engage in such practices.
- Right to withdraw consent: If you have given consent for your data to be processed, you can withdraw it at any time, and we will stop processing your data for that purpose unless legally permitted to continue.
- Right to lodge a complaint: If you are concerned about how we handle your personal data, you can file a complaint with the relevant supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO), which can be contacted online at: Contact us | ICO or by phone at 0303 123 1113. For other EU supervisory authorities, see: Members | European Data Protection Board.
11. EXERCISING YOUR RIGHTS & CONTACTING THE DATA PROTECTION OFFICER
You generally will not need to pay a fee to exercise your rights. However, if your request is unfounded or excessive, we may charge a reasonable fee or refuse to comply with the request.
To exercise your rights, contact [email protected]. We may request additional information to verify your identity. We aim to respond within one month of receiving your request, although complex cases may take longer, in which case we will keep you informed.
Our Data Protection Officer (DPO) is Leah Gallagher, the Head of Compliance.
12. YOUR DUTY TO UPDATE US
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your working relationship with us.
13. WHAT IF YOU DO NOT PROVIDE PERSONAL DATA TO US
You have obligations under your employment contract to provide us with your personal data. You are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide us with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.
Certain information, such as contact details, your right to work in the UK and payment details, may be required to enable EF to enter into a contract of employment with you and pay you. If you do not provide the required information this will hinder or prevent us from administering the rights and obligations arising as a result of the employment relationship.
14. AUTOMATED DECISION MAKING
We do not make employment decisions based solely on automated decision making.
Last updated: May 2025