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This Recruitment 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.
For the purpose of the General Data Protection Regulation (“GDPR”) and the United Kingdom General Data Protection Regulation (“UK GDPR”) and the UK Data Protection Act 2018, the data controller of your personal data in the context of recruitment is Bud Financial Limited.
If and to the extent we are required to appoint a representative in the European Economic Area under Article 27 GDPR, details of our appointed representative (name, address and contact details) will be set out in our main Privacy Notice on our website or notified to you separately. For general data protection enquiries relating to recruitment, you can contact us at dpo@thisisbud.com.
We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. We use Workable to process personal information as a data processor on our behalf. Workable may only process your personal data in accordance with our instructions and our data processing agreement with them.
Where you apply for a job opening posted by us, these Recruitment Privacy Notice provisions will apply to our processing of your personal information in addition to our other Privacy Notice which has been provided to you separately or is available on our Website.
Where 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 in accordance with the Partner’s Privacy Notice.
We collect and process some or all the following types of information from you.
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 and experience that you provide to us, and, where applicable, recordings of video interviews conducted through Workable’s video interview feature.
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.
Details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.
Salary expectations. Portfolio or work samples (where applicable).
In some circumstances, and only where permitted by law, we may also collect special category data (for example, information about disability to support reasonable adjustments, or data for voluntary diversity and equal opportunities monitoring).
Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – for example, professional networking sites (such as LinkedIn), job boards and other platforms where you have made your profile or CV publicly available.
Workable’s technology allows us to search various databases (including publicly available professional profiles and CV databases used for recruitment, which may include your personal data including your CV or Resumé), to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these 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.
Depending on the specific processing activity, we rely on the following lawful bases under UK GDPR / GDPR:
Where we process special category data (such as health information, diversity and equal opportunities data, or information relating to criminal convictions where permitted), we do so only where one of the specific conditions in Articles 9 and 10 GDPR / UK GDPR and relevant UK legislation applies (for example, for employment and social protection law purposes, substantial public interest, or with your explicit consent where required).
We use information held about you in the following ways:
We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.
We may use automated tools to assist with screening and ranking candidates, but we do not make solely automated decisions that produce legal or similarly significant effects on you within the meaning of Article 22 GDPR / UK GDPR. Any decision to offer employment or engagement is made by our staff following human review and consideration.
As set out above, we pass your information to our third party service providers, including Workable, who use it only in accordance with our instructions and as otherwise required by law.
Where you have applied for a job opening through the Indeed Apply functionality, we will disclose to Indeed certain personal data that we hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future 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”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.
Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. 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.
We may also share your personal data with referees and other third parties you have identified, and with regulators, public authorities, law enforcement or courts where we are required to do so under applicable law or regulation.
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
Where we store your personal data in our own systems, it is stored in Workable and our own secure systems.
The data that we collect from you and process using Workable’s Services may be transferred to, and stored at, a destination outside the United Kingdom (“UK”) or the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services.
Where we transfer personal data outside the UK or EEA, we do so in accordance with applicable data protection law and ensure that appropriate safeguards are in place, such as the UK International Data Transfer Agreement or Addendum, the European Commission’s Standard Contractual Clauses, or an adequacy decision by the relevant authority. We do not rely on your submission of personal data as consent to international transfers.
In particular, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any international organisation unless required or permitted under applicable law.
We will hold candidate data for up to 12 months.
Your personal information will be deleted on one of the following occurrences:
In general, we retain data relating to unsuccessful candidates for up to 12 months after the conclusion of the recruitment process for the relevant role, unless we are required to keep it for longer under applicable law or regulation. Where you consent to be considered for future opportunities, we may retain your data for a longer period, which we will explain to you at the point we seek consent. If you become an employee, worker or contractor, your data will be retained and processed in accordance with our employee / worker / contractor privacy notice.
Subject to local data protection laws and in particular under the GDPR and the UK GDPR, you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation and the UK GDPR also give you the right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
Bud Financial Limited is a private limited company registered in England & Wales with registration number 09651629 and address at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, and regulated by the FCA under registration number 793327 (“Bud”, “we”, “us”). Bud is registered with the Information Commissioner’s Office under registration number ZA198709. Bud is committed to protecting and respecting your privacy.
All questions, comments and requests regarding this Privacy Notice should be addressed to help@thisisbud.com.
You can also contact our data protection contact at dpo@thisisbud.com or write to: Bud Financial Limited, 167–169 Great Portland Street, 5th Floor, London, W1W 5PF.
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