Recruitment Privacy Notice

Updated and Effective Date: MAY 20, 2024

Introduction and scope of privacy notice


This Recruitment Privacy Notice explains the type of information we process, why we are processing it, and how that processing may affect you.

What do we mean by “personal data” and “processing”?

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system.  It includes not only facts about you, but also intentions and opinions about you.

“Processing” means doing anything with the data.  For example, it includes collecting it, holding it, disclosing it or deleting it.

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership, and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data” (also known as “special categories of personal data”).

Your personal data

We process your personal data for the purposes of fulfilling our recruitment practices.  Some of the personal data that we process about you comes from you.  For example, you tell us your contact details.  Other personal data about you is generated from references and third party companies such as recruitment agencies.  Your personal data will be seen internally by managers, administrators and HR.

How long do we keep your personal data?

If you are successful in your application your data will be kept on your personnel file.  If you are unsuccessful, your data will normally be deleted twelve months after you have been informed that you were unsuccessful. Data which is not relevant to your application may be deleted after a short period.

Transfers of personal data outside the EEA

We are headquartered in the United States and we have offices in the UK, EU, and India.  Therefore, we may transfer your personal data between these jurisdictions to members of our group.  We may also transfer it to processors (service providers) in other countries.  We will ensure that the transfer is lawful and that there are appropriate security arrangements in place to secure your personal data).

We have entered into agreements ensuring appropriate and suitable safeguards with our group members and third party service providers, including use of standard contractual clauses approved by the European Commission and, as adapted, the UK Information Commissioner’s Office.  If you wish to be provided with additional details about these safeguards, please email

Contact details

In processing your data we, and in some cases our group companies, act as a data controller. 

If you have any questions relating to our processing of your personal data, please contact us at

Legal grounds for processing personal data

What are the grounds for processing?

Under data protection law, there are various grounds on which we can rely when processing your personal data.  In some contexts more than one ground applies.  Two of those grounds (upon which we rely, as further detailed in the second table, below) can be summarised as Legal Obligation and Legitimate Interests.  We outline what those terms mean below:


Ground for processing


Legal Obligation

Processing necessary to comply with our legal obligations

Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.

Legitimate Interests

Processing necessary for our or a third party’s legitimate interests

We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.

Processing sensitive personal data

If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one of the grounds for processing sensitive personal data also applies.

Further information on the data we process and our purposes

Examples of the data and the grounds on which we process data are in the table below.  The examples in the table cannot, of course, be exhaustive.


Examples of personal data that may be processed

Grounds for processing


Information concerning your application and our assessment of it, the fact of your application and our record of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work. If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements.

Legal obligation

Legitimate interests

Contacting you or others on your behalf

Your address and phone number, emergency contact information and information on your next of kin

Legitimate interests

Who gets to see your data?

Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this Notice.  We may also disclose this to other members of our group and to our recruitment service providers.

Access to your personal data and other rights

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and an explanation of why we are processing it.

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. You may also have the right to be given your data in a machine readable format for transmitting to another data controller though this right is unlikely to be relevant to you in the context of our recruitment processes.

We are unlikely to rely on consent as a ground for processing. However, if we do, you may withdraw consent at any time — though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.


If you have complaints relating to our processing of your personal data, you should raise these with the P&C team in the first instance by contacting may also raise complaints with the statutory regulator in your jurisdiction.