Candidate privacy policy

Mind Gym plc is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR). 

We will comply with data protection law and principles, which means that your data will be: 

• Used lawfully, fairly and in a transparent way. 

• 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. 

• Kept securely. 

The kind of information we hold about you 

• In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you: 

• The information you have provided to us in your curriculum vitae and covering letter. 

• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, your desired level of remuneration, your previous remuneration including benefit entitlements. 

• Any information you provide to us during an interview. 

• Any information you provide to us in an assessment (MindGym uses personality, cognitive and motivation assessments in its hiring process where appropriate). 

• The results of any assessments we give you, including online tests. 
• Outcomes of the recruitment process. 

We may also collect, store and use the following types of more sensitive personal information: 

• Information about your health, including any medical condition, health and sickness records, and in particular if you have asked us to make reasonable adjustments during the recruitment process, information about your disability. 

• Information about criminal convictions and offences. 

How is your personal information collected? 

We collect personal information about candidates from the following sources: 

• You, the candidate. 

• Recruitment agency 

• Your named referees, from whom we collect information relating to your performance on the job, but only after you’ve accepted our conditional offer. 

• The following data from third parties is from a publicly accessible source such as LinkedIn. 

We will use the personal information we collect about you to: 

• Assess your skills, qualifications, and suitability for the role or work that you are contracted for. 

• Communicate with you about the recruitment process. 

• Keep records related to our hiring processes and outcomes. 

• Comply with legal or regulatory requirements. 

We process this information as part of our legitimate interests as we need to decide whether to appoint you to a role for our benefit. We also need to process your personal information to decide whether to enter into a contract of employment with you. 

Having received your CV and any covering letter or application and potentially the results from any telephone calls, email exchanges with you, or outcomes of previous assessments, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you work. If we decide to make you an offer, we will then take up references before confirming your appointment. 

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. 

• We will use your particularly sensitive personal information in the following ways: 

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview. 
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. 

In the early stages of our recruitment process, we use the automated screening and interview platform BrightHire (powered by BrightHire, Inc) to assist with initial review of applications. BrightHire helps structure and summarise candidate responses consistently and efficiently. Use of BrightHire is supplementary: all substantive hiring decisions remain subject to human review. Any personal data processed via BrightHire is handled in accordance with this Privacy Policy.

Why might you share my personal information with third parties? 

We will only share your personal information with other companies within our group as opportunities may arise in those companies and our data processors necessary for us to process your application. All of our group companies are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Data security 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our data protection officer. Please see below. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

How long will you use my information for? 

We will retain your personal information for a period of 2 years after we have communicated to you our decision about whether to appoint you. We retain your personal information so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We also retain your personal information for a period of 2 years on the basis that a further opportunity may arise in the future, and we may wish to consider you for that. 

After this period, we will securely destroy your personal information in accordance with our data retention policy, unless you are being considered for a subsequent opportunity.