Data Processing for Recruitment Policy

As part of any recruitment process, Substrakt will collect personal data relating to job applicants. Substrakt is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information do we collect?

Substrakt will collect a range of information about you, which includes:

  • Your name, address, contact details, including email address and telephone number.
  • Details of your qualifications, skills, experience and employment history. Substrakt will never ask you to provide your current salary information.
  • Information about your entitlement to work in the UK.
  • And equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

How do we collect this information?

Personal data may be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessments.

We may also collect personal data about you from third parties, such as references supplied by former employers. If we seek references from third parties we will do so only once a job offer has been made to you, and we will inform you that we are doing so.

All applicants are added to our recruitment software (Workable). Workable’s data processing activities are governed by a contract that complies with EU law. In addition to keeping a record of your application documents and communication, Workable automatically searches the internet for other relevant information about each applicant including social media profiles, profile images, and email addresses.

Data will be stored in a range of different places, including emails, our recruitment software (Workable), internal messaging systems (Slack) and secure data stores that are only accessible to the HR team and the team responsible for your appointment.

Why do we process personal data?

Substrakt needs to process data that you provide prior to and at the point of entering a contract with you. In some cases, Substrakt needs to process data to ensure that we are complying with our legal obligations. For example, it is required that we have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Substrakt to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide whom to offer a job to. 

Substrakt processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment. Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is only for equality, diversity and inclusion monitoring purposes.

Substrakt will not use your data for any purpose other than the recruitment exercise for which you have applied.

If your application is unsuccessful, Substrakt will keep your personal data on file for up to 6 months, in case there are future employment opportunities for which you may be suited. 

You are free to withdraw your consent at any time by contacting

Who has access to recruitment data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team and interviewees involved in the recruitment process, and managers in the relevant business area.

Occasionally, Substrakt may use a third party recruitment agency to manage the recruitment process, who will have access to your application data via our HR software (Workable).

We will not share your data with any other third parties, unless your application is successful and we make you an offer of employment. It may then be necessary to share your data with the individuals you provide as references.

We will only transfer your data outside of the EEA if you are a foreign national or have previously worked internationally. Any data transfer will be for the sole purpose of obtaining a reference from a referee outside of the EEA or for the purposes of facilitating a visa application where necessary.

How do we protect recruitment data?

Substrakt takes the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees or a third party recruitment consultant who have been given permission by us to do so, in order to perform their duties. Applications may only be accessed by the HR team and the hiring team responsible for a particular vacancy. Your data will not be shared internally other than for the processing of your application for employment.

How long do we keep recruitment data?

If your application is unsuccessful, Substrakt will hold your data on file for 6 months after the end of the relevant recruitment process. For some applicants, we may ask to keep your data on file for consideration for future employment opportunities. If consent is given by the applicant, their data will be held on file for a further 12 months for consideration for future employment opportunities.

If your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment with Substrakt. The periods for which your data will be held will be provided to you in a new employee privacy notice.

Your rights

Substrakt’s policies do not affect your rights under the Data Protection Act 2018. Under the data Protection Act you can:

  • Access and obtain a copy of your data on request
  • Require Substrakt to change incorrect or incomplete data
  • Require Substrakt to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
  • Object to the processing of your data where Substrakt is relying on it’s legitimate interests as the legal ground for processing
  • Ask Substrakt to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Substrakt’s legitimate grounds for processing data

If you would like to exercise any of the above rights, please contact us.

If you believe that Substrakt has not complied with your data protection rights, you can complain to the Information Commissioner here.

What if you do not wish to provide personal data?

You are under no statutory or contractual obligation to provide data to Substrakt during the recruitment process. However, if you do not provide the information, we may not be able to process your application effectively.

Decision making

Our recruitment processes are not based on automated decision making. We personally review all applications that are submitted to us.