GDPR Recruitment Privacy Notice

Data controller: Blueberry Wave Ltd, 22 Thomas Street, Cirencester, GL7 2BD

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

What personal data do we collect?

We collect 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
  • whether or not you have a disability for which the Company needs to make reasonable adjustments
    during the recruitment process
  • information about your entitlement to work in the UK.

We may collect this information in a variety of ways e.g. data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

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

Data will be stored in a range of different places, including in HR management systems/or/digital folders and on other IT systems (including email).

Why do we process personal data?

We need to process personal data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that it is complying with its legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.

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 us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

We may also collect information about any disabilities candidates may have to allow us to make reasonable adjustments where required. We process such information to carry out our obligations and exercise specific rights in relation to employment.

Who has access to personal data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes directors, members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you.

We will not transfer your data outside the European Economic Area.

For how long do we keep data?

If your application for employment is unsuccessful, we will hold your data on file for one year after the end of the relevant recruitment process.

If we wish to and you agree to allow us to keep your personal data on file, we will hold your data on file for one year for consideration for future employment opportunities. At the end of that period (or once you withdraw your consent), your data will no longer be retained for that purpose.

If you have submitted a cv for consideration when there is not a specific vacancy we may keep your personal data on file for one year in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time, in which case your data will no longer be retained for that purpose.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file. The periods for which your data will be held will be provided to you in our Data Protection and Data retention Policies.

How do we protect personal data?

We take the security of your data seriously and 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 in the proper performance of their duties. Blueberry Wave is ISO 27001:2013 certified, and this management system has ensured a range of security controls are in place throughout the business for the purposes of protecting both electronic and hard copy information and data.

Your rights

Under the General Data Protection Regulation (‘GDPR’) and the Data Protection Act 2018 (the ‘2018 Act’) you have a number of rights with regard to your personal data:

You have the right:

  • to access and obtain a copy of your data on request
  • to require us to change incorrect or incomplete data
  • to require us to delete or stop processing your data, for example where the data is no longer
    necessary for the purposes of processing
  • to object to the processing of your data where we are relying on our legitimate interests as
    the legal ground for processing.

If you would like to exercise any of these rights, please contact

If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner. Full contact details including a helpline number can be
found on the Information Commissioner’s Office website. This website has further information on your rights and our obligations.

What if you do not provide personal data?

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

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

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