Job Applicant Privacy Notice
Data Protection Representative: Chief Technology Officer (Data Protection Lead)
Purpose of this notice
Thinventory is committed to protecting the privacy and security of your personal information.
As part of any recruitment process, Thinventory collects and processes personal data relating to job applicants. Thinventory is committed to being transparent about how it collects and uses that data, in accordance with Data Protection Legislation.
Data protection principles
Thinventory will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent manner;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
What information does Thinventory collect?
Thinventory collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- 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 data
Thinventory may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport (should you be successful in your application) or other identity documents, or collected through interviews or other forms of assessment including online tests.
Thinventory may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Thinventory will seek information from third parties only once a job offer to you has been made and you have provided your consent to do so.
Data may be stored in a range of different places, including on your application record, in HR management systems both of which may be cloud based and on other IT systems (including email).
Why does Thinventory process personal data?
Thinventory needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, Thinventory needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
Thinventory has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Thinventory to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Thinventory may also need to process data from job applicants to respond to and defend against legal claims.
For some roles, Thinventory is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
Thinventory will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, IT staff if access to the data is necessary for the performance of their roles and the legal team should an applicant be successful in order to create the contract of employment.
Thinventory will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Thinventory will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
Your data may be transferred outside the United Kingdom (UK) to allow the business to operate effectively and efficiently. Data may be transferred outside the UK to support organisational growth. An example of which may include shared services or the provision of shared services which will operate globally. Any transfer will be subject to appropriate safeguards and binding corporate rules, which may also include the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or reliance on the “data protection test” introduced by the Data (Use and Access) Act 2025 (protection not materially lower than under the UK GDPR).
How does Thinventory protect data?
Thinventory takes the security of your data seriously. It has 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 appropriate employees in the proper performance of their duties. Our Information Security Statement can be found here. In addition, the policy detailing Employee Data Protection Obligations can be found here.
How long does Thinventory keep data?
If your application for employment is unsuccessful, Thinventory will hold your data on file for up to six months after the end of the relevant recruitment process. If you agree to allow Thinventory to keep your personal data on file, Thinventory will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Thinventory to change incorrect or incomplete data;
- require Thinventory to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where Thinventory is relying on its legitimate interests as the legal ground for processing; and
- receive, or ask Thinventory to send to another organisation, the personal data you have provided to Thinventory, in a structured, commonly used, machine-readable format, where the processing is based on consent or on a contract with you and is carried out by automated means.
When you ask to access your data, Thinventory will carry out reasonable and proportionate searches to locate it and will normally respond within one month of receiving a valid request. Where a request is complex, or you have made a number of requests, this may be extended by up to two further months, and we will tell you within the first month if this applies and why. Where we reasonably need to verify your identity, or need clarification of the scope of your request, the one-month period will not start, or will be paused, until we receive the necessary information.
If you would like to exercise any of these rights, please contact the Data Protection Lead at [email protected].
Data protection complaints
Thinventory tries to meet the highest standards when collecting and using personal information.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspect of Thinventory’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
If you have any questions or concerns about Thinventory’s Privacy Policy or data processing, or if you would like to make a complaint, please contact the Data Protection Lead at [email protected]. We will acknowledge your complaint within 30 days of receiving it, take appropriate steps to investigate, respond without undue delay, and keep a record of how your complaint was handled.
We encourage you to complain to us first, so that we have the opportunity to put things right. Under the Data (Use and Access) Act 2025, the Information Commissioner’s Office (ICO) generally expects individuals to have raised their complaint with us, and given us a reasonable opportunity to respond, before it will investigate a complaint made directly to it, save in exceptional circumstances. If you are not satisfied with our response, or we have not resolved your complaint within a reasonable time, you can complain to the ICO: www.ico.org.uk/make-a-complaint, or 0303 123 1113.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
Automated decision-making
Our current recruitment processes are not based on automated decision-making.
If this changes and Thinventory were, for example to begin using automated screening or scoring of applications that produces a legal effect or similarly significant effect on you, we will tell you, and, in accordance with the Data (Use and Access) Act 2025, we will: give you information about the decision; give you the opportunity to make representations about it; provide access to meaningful human intervention on request; and allow you to contest the decision. We will not use special category data (such as data about your health, ethnicity or religion) to make a solely automated decision about you unless you have given explicit consent or another legal exception applies.
