Privacy Policy – Recruitment

1 Introduction

Likezero Limited (“we”, “us”, “our”) is committed to protecting your privacy and ensuring that your personal information is handled in accordance with applicable data protection laws.

This Recruitment Privacy Policy explains how we collect, use, and protect your personal data during the recruitment process. It applies to all applicants, contractors, interns, and prospective directors (“candidates”, “you”), regardless of whether the recruitment process results in you becoming an employee.

We are the data controller of your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy should be read together with any other related privacy information or notices we may provide to you, so that you fully understand how and why we use your information.

Our Data Protection Officer (DPO) is Brett Aubin, who oversees compliance with this policy.

If you have any questions about this policy or how we use your information, please contact us:

Address: Likezero Limited, 51 Eastcheap, London, EC3M 1DT

Email: dpo@likezero.co.uk

We are registered with the Information Commissioner’s Office (ICO) under registration number ZC007912.

We may update this policy from time to time. A copy of our most up to date policy can be requested by emailing hr@likezero.co.uk.

 

2 Data protection principles

We comply with the data protection principles set out in the UK GDPR and the Data Protection Act 2018. This applies to both electronic and paper-based data. We ensure that your personal data is:

  • Processed lawfully, fairly, and transparently
  • Collected for specified, explicit, and legitimate purposes
  • Adequate, relevant, and limited to what is necessary
  • Accurate and kept up to date
  • Retained only as long as necessary
  • Kept secure and protected from unauthorised access
  • Not transferred outside the UK unless adequately protected

“Personal data” means any information relating to an identified or identifiable individual. It does not include data that has been anonymised.

 

3 What personal data we collect

We collect and process personal data necessary to manage the recruitment process, assess your suitability for employment, and comply with legal obligations.

Personal information

  • Name, address, email address, and telephone number
  • Details of your qualifications, skills, experience, and employment history
  • Referee contact details
  • Information about your nationality and right to work in the UK (e.g. passport, visa)

Additional information (where relevant) 

  • Health or disability information to make reasonable adjustments
  • Equal opportunities data (e.g. ethnicity, gender, religion or belief, sexual orientation)
  • Criminal record information, including results of Disclosure and Barring Service (DBS) checks
  • Driving licence details (for identity verification)

Other information

  • Information you provide during interviews or assessments
  • Information from referees, background check providers, or recruitment agencies
  • Any other data necessary to comply with legal obligations and exercise our rights as a prospective employer

We only collect data that is relevant and necessary for the recruitment process.

 

4 Special category and criminal data


Special category data

Some of the information we collect is considered special category data, such as data revealing racial or ethnic origin, religious beliefs, health information, or sexual orientation. We apply additional safeguards when processing such data.

We process special category data where one of the following conditions applies:

  • Employment, social security and social protection law (Article 9(2)(b) UK GDPR and Schedule 1, Part 1, paragraph 1 of the Data Protection Act 2018) – This applies when we process health information for reasonable adjustments, or diversity data for equality monitoring.
  • Explicit consent (Article 9(2)(a)) – Where we process special category data with your explicit, freely given consent for specific purposes.
  • Data made public by you (Article 9(2)(e)) – Where you have deliberately made the information public.
  • Legal claims (Article 9(2)(f)) – Where necessary to establish, exercise, or defend legal claims.
  • Substantial public interest (Article 9(2)(g) and Schedule 1, Part 2 of the Data Protection Act 2018) – Where necessary for reasons of substantial public interest.

Criminal Conviction Data

For criminal conviction data (including DBS checks), we rely on Schedule 1, Part 1, paragraph 1(1)(a) of the Data Protection Act 2018, which permits processing for employment purposes where authorised by law.

 

5 How we collect your data

We collect personal data in various ways during the recruitment process, including:

Directly from you:

  • Application forms, CVs, and covering letters
  • Emails, letters, or other communications
  • Conversations, interviews, meetings, or assessments
  • Identity and right-to-work documents (e.g. passport or driving licence)

From third parties:

  • Recruitment agencies acting on your behalf (we will confirm which agency if applicable)
  • Referees or previous employers (only with your permission or where you have provided their details)
  • Background screening providers [add specific providers if known, e.g., Sterling, Experian]
  • The Disclosure and Barring Service (DBS), where the role requires this
  • Occupational health professionals (only where necessary for reasonable adjustments)
  • Government departments or regulatory authorities (e.g., Home Office for right-to-work verification)

We will inform you before obtaining information from third parties unless we are legally prevented from doing so.

From public sources:

  • Professional networking sites (e.g. LinkedIn)
  • Publicly available databases or company websites

We only collect information from third parties where it is relevant, lawful, and necessary for recruitment purposes.

 

6 How we store and protect your data

We take the security of your personal data seriously and apply appropriate technical and organisational measures to protect it.

Your data may be stored in:

  • Secure electronic systems (e.g. Google Workspace)
  • Physical files at our offices (where required)
  • Trusted third-party platforms used for recruitment

Security measures 
We use the following measures to protect your data:

  • Encryption (in transit and at rest)
  • Multi-factor authentication
  • Role-based access controls
  • Regular security testing and monitoring
  • ISO 27001-certified information security practices
  • Formal data handling and breach response procedures

If a data breach occurs that may pose a risk to your rights or freedoms, we will notify you and the ICO as required by law.

Data retention 

Unsuccessful candidates: Data is retained for 6 months after the recruitment process ends. This allows us to:

  • Respond to any queries about your application
  • Defend against potential legal claims
  • Consider you for other suitable roles that may arise

You may consent to us retaining your data for up to 12 months if you wish to be considered for future opportunities. You can withdraw this consent at any time by emailing hr@likezero.co.uk.

Successful candidates: Relevant data will form part of your personnel record and be processed in line with our Employee Privacy Policy.

We may retain data longer if necessary for legal, compliance, or audit purposes.

Data that is no longer required is securely deleted or anonymised.

 

7 How we use your personal information

We will only use your data for the purpose it was collected, unless another lawful and compatible purpose applies. We process your data only when lawful and necessary to:

  • Assess your qualifications, skills, and suitability for employment
  • Communicate with you about your application
  • Verify information and conduct right-to-work or reference checks
  • Comply with legal obligations
  • Maintain recruitment records and equality monitoring data
  • Protect our legal rights

If you choose not to provide information we reasonably request, we may not be able to consider your application fully or comply with legal obligations.

Legal basis for processing

Under Article 6 of the UK GDPR, we process your personal data on the following legal bases:

  • Legitimate interests (Article 6(1)(f)) – We have a legitimate interest in assessing candidates for employment and managing our recruitment process effectively. This is balanced against your rights and freedoms, and we believe you would reasonably expect this processing when you apply for a role with us.
  • Contract (Article 6(1)(b)) – Where you have been offered a position, processing is necessary to take steps at your request prior to entering into an employment contract.
  • Legal obligation (Article 6(1)(c)) – We must process certain data to comply with employment law, immigration law, and other legal requirements (e.g., right-to-work checks, health and safety obligations, tax and national insurance).

Automated decision-making and profiling

We do not use solely automated decision-making (including profiling) in our recruitment process that produces legal or similarly significant effects. All hiring decisions involve meaningful human review and assessment by our recruitment team.

 

8 Sharing your data with others

We may share your personal data only where necessary and lawful, including with:

  • Recruitment agencies or consultants
  • Background screening or reference providers
  • Occupational health professionals
  • Professional advisers (legal, HR, or audit)
  • Government or regulatory authorities (e.g. Home Office, HMRC)
  • Technology and system providers supporting our recruitment process

We ensure all third parties handle your data securely and in accordance with data protection law. Information is shared anonymously or pseudonymised wherever possible.

We do not sell or share your data for marketing purposes.

 

9 Transferring your data outside the UK

Some of our service providers (such as Google) may store or process data outside the UK.[Text Wrapping Break] When this occurs, we ensure your data remains protected by:

  • Transferring only to countries recognised by the UK government as providing adequate protection; or
  • Using UK International Data Transfer Agreements (IDTA) or Standard Contractual Clauses (SCCs) to safeguard your data.

We also apply encryption, access control, and monitoring measures to protect transferred data.

Likezero is ISO 27001 certified, ensuring compliance with recognised information security standards.

For more details about these safeguards, contact hr@likezero.co.uk.

 

10 Your rights in relation to your data

Under UK data protection law, you have the right to:

  • Access – Request a copy of the personal data we hold about you.
  • Rectification – Request correction of inaccurate or incomplete data.
  • Erasure – Request deletion of your data in certain circumstances.
  • Restriction – Request restriction of processing in limited cases.
  • Data Portability – Request to receive or transfer your data to another organisation.
  • Objection – Object to processing based on our legitimate interests.
  • Automated Decisions – Object to automated decisions that produce legal or significant effects.

We respond to all valid requests within one month. Complex requests may take up to two additional months; if so, we will inform you.

You may exercise these rights by contacting us:

Email: hr@likezero.co.uk

Post: Likezero Limited, 133 Park St, SE1 9EA, London

You will not be charged for exercising your rights unless your request is clearly unfounded or excessive.

For full details, see the UK GDPR or guidance from the ICO at www.ico.org.uk.

 

11 Making a complaint

If you have concerns about how we handle your personal data, please contact our Data Protection Officer first:

Email: hr@likezero.co.uk

Post: Data Protection Officer, Likezero Limited, 133 Park St, SE1 9EA, London

If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office (ICO):

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk

 

12 Updates to this policy

We may update it periodically to reflect legal or operational changes.

Any significant updates will be published on our website and, where appropriate, communicated directly to candidates.

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