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HR Candidate Submission Privacy Policy

1 Privacy Notice for recruitment

Adaptavist Group LTD ("We", "we", "Us", "us") are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. In addition, please review our general Privacy Policy, which is applicable to general use of Adaptavist websites and services, and interaction with the company.
If you do not agree with this Privacy Notice or the general Privacy Policy (or any other policy referenced therein), do not put forward your details or apply for a position at Adaptavist.
This privacy notice was last updated in May 2026

2 Your Personal Information

2.1 Information we collect from you
We collect and process some or all of the following types of information from you throughout the recruitment process:
  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person, at interviews and/or by any other method. In particular, we process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using the video interview feature
  • We may also collect equal opportunity and diversity data, if you choose to provide this. This data is kept separate from your application and used to help us understand our applicants and monitor the effectiveness of our inclusive hiring practices
  • If you contact us, we may keep a record of that correspondence.
  • A record of your progress through any hiring process that we may conduct and associated information
  • Details of your visits to third-party service providers including, but not limited to, traffic data, location data, weblogs and other such communication data, the site that referred you to the third-party service provider, and the resources that you access.
  • If your application is successful, we use third parties to carry out pre-employment screening checks as part of our onboarding. Depending on the role you have applied for, this may include criminal record checks.
2.2 Information we collect from other sources
We may use our own technology or a third-party service provider to link the data you provide to us with other publicly available information about you that you have published on the internet, including professional networking sites e.g. LinkedIn("Public Sources"), .
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Certain third-party service providers allow us to search various databases. Some of these are publicly available and others not. These databases may include your personal data (such as your CV or Resumé), and we search such databases to find possible candidates to fill our job openings. When we find you in this way, we obtain your personal data from these sources.
2.3 Successful applications
As part of our pre-employment process, we carry out background checks to verify the information you have provided and meet any legal or regulatory obligations. The scope of checks conducted will depend on the nature of your role and the location of the role you have applied to. Background checks are only initiated once an employment offer has been accepted.

3 Why and how we use your information

3.1 Purposes of processing
We may use information held about you in the following ways:
  • To consider your application in respect of a role for which you have applied
  • To consider your application in respect of other roles which match your interests and expertise
  • To manage our recruitment process and communicate with you in respect of your application and other similar role opportunities
  • To enhance any information that we receive from you with information obtained from third party data providers
  • To conduct our recruitment interview process, including evaluating your suitability for the role during interviews
  • To facilitate our onboarding process (such as sharing an offer of employment and sharing your details with our third party pre-employment screening provider)
  • To find appropriate candidates to fill our job openings
  • To help our service providers and Partners (such as the job sites through which you may have applied) improve their services, which in turn helps us improve our processes.
  • To conduct analysis to understand our recruitment process and practices further, for example reporting on source of applications and use of our Partners
3.2 Lawful basis for processing
  • Legitimate Interests
We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business, including to confirm suitability for the role. When a candidate accepts an offer of employment, we may rely on legitimate interests to carry out pre-employment screening.
  • Consent
When you apply for a job opening through a third-party service provider, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to that third-party service provider on the basis described below.
If you choose to join our talent community, we will rely upon consent and you can withdraw this at any time.
Depending on where you are based, we may rely on your consent to process equal opportunity data.
In certain countries, we rely on consent in order to conduct background screening
  • Substantial public interest
Depending on where you are based, you may be asked to provide equal opportunity and diversity information. This is optional and we rely on substantial public interest, to identify or keep under review the existence or absence of equality of opportunity or treatment.
  • Legal obligation
In some countries, we have a legal obligation to carry out pre-employment checks to ensure an individual is eligible to work in that country.
3.3 Automated decision making/profiling
We may use technology to highlight appropriate candidates for us to consider based on criteria expressly identified by us, or based on what is typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic. We may use Artificial Intelligence (AI) to support the recruitment process. However, any decisions about a candidate will be made by our staff (for example, whether to initiate discussions, progress or reject a candidate)

4 Disclosure of Your Information

We use third-party service providers to support our recruitment process:
4.1 Third party provider: SmartRecruiters
SmartRecruiters is our Applicant Tracking System. We use SmartRecruiters to manage applications, schedule interviews, record feedback and facilitate any offers. SmartRecruiters is only entitled to process your personal data in accordance with our instructions. SmartRecruiters privacy policy is available here
4.1 Third party provider: Screening
We use Checkr and Zinc as our third party background screening providers. To carry out checks, we will share limited information in order for the provider to send you an invite to their secure platform, where you will be asked to submit supporting information and documentation including a copy of your passport and proof of address.
Zinc’s privacy policy is available at: https://zincwork.com/website-privacy-policy
4.2 Other third-party service providers
Where you have applied for a job opening through a third-party provider, and where you have consented to this disclosure, we may disclose to that third-party provider certain personal data that we hold, including but not limited to a unique identifier used by that provider to identify you, and information about your progress through our hiring process for the applicable job opening, as well as other information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively "Disposition Data"). The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.
Other third-party providers may include (but are not limited to):
  • Indeed.com (via Indeed Apply functionality). Indeed’s privacy policy is available here
4.3 Partners
When you apply for a job opening via the application function on a job site or similar online service provider ("Partner"), you should note that the relevant Partner may retain your personal data and may also collect data from us in respect of the progress of your application. Any use by the Partner of your data will be subject to the Partner’s privacy notice. Partners include:

5 Public Sources

Public sources may include sources such as LinkedIn and other social media profiles. Public sources may also include Partners.

6 Security and data retention

6.1 Security measures
We employ security measures based on ISO 27001 to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction, damage and unauthorised alteration. How long we keep information we collect about you depends on the type of information. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. Only authorised employees have access to the information you provide us.
You are ultimately responsible for the security of any usernames and passwords we supply to you. Please take care when using and storing them. Adaptavist recommends that you do not divulge your password to anyone. You should log out of your browser at the end of each computer session to ensure that others cannot access your personal information and correspondence, especially if several people have access to your personal computer or you are using a computer in a public place.
As part of the requirements of the General Data Protection Regulation (GDPR), Adaptavist has registered with the Data Commissioner in the United Kingdom and you can see our notification report on their website.
6.2 Transferring data
Data on our Applicant tracking system is stored within EU data centres. If we are required to transfer personal data outside of the EU, Adaptavist relies upon i) adequacy decisions ii) agreements which include European Commission Decision 2021/914 requirements for those transfers and/or iii) accredited compliance frameworks applicable to a country to transfer data across geographies
6.3 How long we keep your personal data
The length of time we hold your personal data will vary depending on the outcome of our interaction with you. Some specific scenarios include:
  • You become a candidate, but not an employee: In this case, we will hold your information by default for up to 24 months in order to have a record of your application, and for any further follow-up discussions we may have with you.
  • You join our talent community, in which case we will keep your data for as long as you wish to be a member
  • You become an employee: In this case, we may hold personal data you submit for the duration of your tenure as an employee, and quite possibly beyond this period in order to maintain record of your employment.

7 Your Data Protection Rights Under GDPR

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8 Your rights under the California Consumer Privacy Act (CCPA)

In addition to, and in compliance with the foregoing terms, where prospective Adaptavist candidates or Adaptavist Employees are California residents the following section shall apply. This section shall not however apply to any deidentified or aggregated Personal Information. All undefined terms herein shall have the meaning ascribed to them under The California Consumer Privacy Act of 2018.
Under the CCPA Consumers retain the right to know what Personal Information is collected by Adaptavist, the right to know if such Personal Information is being sold under the CCPA, the right to object to the sale of Personal Information, the right to access Personal Information, and the right to the deletion of Personal Information.8.1 Categories, Sources, and Purposes of Your Personal Information Collected
8.1.1 Categories of Personal Information Collected
This is as described in section 2.1.
8.1.2 Business or Commercial Purposes
The business or commercial purposes for which the categories of Personal Information will be collected or used, or was collected or used during the 12-month period prior to the effective date of this Policy, are as described in section 3.
8.1.3 Categories of Sources
The categories of sources from which Personal Information was collected during the 12-month period prior to the effective date of this Policy are as described in sections 4 and 5.
8.1.4 Categories of third parties to whom Personal Information is disclosed
This is as described in section 4.
8.2 The sale of Personal Information
The CCPA grants Consumers the right, at any time, to direct a business that sells Personal Information about the Consumer to third parties not to sell the resident’s Personal Information. Adaptavist does not sell your Personal Information under the CCPA.
8.3 The right to access Personal Information
The CCPA grants the right to request disclosure of Consumers’ Personal Information in a readily usable format and to receive details regarding the use and purpose of any Personal Information collected by Adaptavist, including any third parties with which your Personal Information may be shared. Adaptavist shall aim to respond to all verifiable requests within 45 days of receiving the request.
8.4 The right to deletion of Personal Information
Subject to statutory exceptions the CCPA grants the right to the deletion of Personal Information upon request by a Consumer. Adaptavist may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal or regulatory obligations. If your request is subject to any statutory exceptions Adaptavist shall inform you of the reasons for retaining your Personal Data. If you ask us to delete it, you may no longer be able to apply at Adaptavist.
8.5 Exercising these Rights
If you would like to exercise any of the rights stated herein, please:
  • contact us using our Contact details below,
  • provide us with information to identify you,
  • provide us with proof of your identity and address, and
  • let us know the information to which your request relates.
Adaptavist shall not discriminate against you for exercising any of the rights stated herein, nor shall it in any way affect the recruitment process.

9 Data Controller & contact information

The Adaptavist Group is a multinational group of companies operating worldwide. The Data Controller for your personal data will be the entity based in the location of the role you are applying for. All questions, comments and requests regarding this Privacy Notice or our privacy practices, regardless of location, should be addressed to our central privacy team at legaloperations@adaptavist.com
  • If you are applying for a job in the United Kingdom, the data controller is ARUK Global Limited, whose registered office is at 25 Wilton Road, Victoria, London, United Kingdom.
  • If you are applying for a job in Germany, the data controller within the meaning of The General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG) is Adaptavist Germany GmbH, whose registered office is Blaubach 32 50676 Cologne, Germany.