Privacy Policy
1. Introduction
This Privacy Policy explains how Reconomy Group ("we", "us", "our", "company'') collects, uses, stores, and shares personal data submitted by job applicants ("you", "your") through our Applicant Tracking System (ATS) named PinPoint.
We are committed to protecting your privacy and complying with the Data Protection Laws.
2. Definitions
“Data Protection Laws”: Means applicable law and regulatory requirements relating to the processing, privacy and use of personal data and protection of individuals, including, but not limited to:
(i) Regulation (EU) 2016/679 (“GDPR”)
(ii) Regulation (EU) 2016/679 (“GDPR”) as incorporated into domestic UK law by the European Union (Withdrawal Agreement) Act 2020 and amended by The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2020 (together the “UK GDPR”).
(iii) any legislation enacted in the country of establishment of the data controller in respect of the protection of personal data or any corresponding or equivalent national laws or regulations.
all as amended, updated, or replaced from time to time;
“Relevant Guidance”: means
(i)guidance and codes of practice issued from time to time by a data protection regulator and/or the European Data Protection Board (previously known as the Article 29 Working Party); and
(ii)any relevant case law, court order, judgment or decree under applicable law and regulatory requirements.
“Domestic Law”: Means the laws of the country of establishment of the data controller.
“Personal Data”: Means any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, such as a name, identification number, location, online identifier.
3. What Personal Data We Collect
We may collect the following categories of personal data:
· Full name and contact details (email, phone, address)
· CV/resume, cover letter, employment history, education
· Job preferences and application details
· Interview notes and assessments
· Equal opportunity data (e.g., gender, ethnicity, disability status) – optional
· IP address and usage data (for platform security and analytics)
4. Legal Basis for Processing
We process your data under the following lawful bases:
· Legitimate Interest: To assess your suitability for roles and manage recruitment
· Contractual Necessity: To take steps prior to entering into a contract
· Legal Obligation: To comply with employment and anti-discrimination laws
· Consent: For optional data (e.g., equal opportunity monitoring) and marketing communications
5. How We Use Your Data
We use your personal data to:
· Manage your job applications
· Communicate with you during the recruitment process
· Evaluate your qualifications and suitability
· Conduct background checks (where applicable, based on local legislation)
· Improve our recruitment processes and platform
6. Data Sharing
We may share your data with:
· Entities within Reconomy Group [CR1] using our platform to recruit
· Background check providers (with your consent)
· IT service providers (for platform hosting and maintenance)
· Legal or regulatory authorities (if required by law)
All third parties are bound by data protection agreements and must comply with Data Protection Laws.
7. Data Retention
We retain your data for no longer than necessary:
· Unsuccessful applicants: Up to 12 months after application
· Successful applicants: As per employment contract and legal obligations
You may request earlier deletion (see Section 9).
9. Your Rights
Under GDPR, you have the right to:
· Access your data
· Rectify inaccurate data
· Erase your data ("right to be forgotten")
· Restrict or object to processing
· Data portability
· Withdraw consent at any time
10. International Transfers
If your data is transferred outside the UK or EU, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions.
Due to the international nature of the Company’s operations, personal data may be disclosed to countries outside of the UK and/or the European Economic Area (EEA). If a Company controller transfers personal data to a third country i.e., outside the European Economic Area for an EU Controller or outside the UK for a UK Controller, the Company will seek to put in place appropriate safeguards to ensure that personal data remains adequately protected. We will ensure that all legal requirements in respect to international data transfers will be followed.
12. Complaints
If you believe your data rights have been violated, you can contact:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
ICO website: https://www.ico.org.uk
You can also complain to your local Supervisory Authority (“SA”) if you are unhappy with how we have used your data.
A list of EU SAs is maintained by the European Data Protection Board (EDPB) and can be accessed here.