Privacy Policy

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Your new rights under the GDPR are set out in this notice, and were last updated on 23rd May 2018.

The Information we collect

To carry out our core recruitment activities, we collect information about you which may include: your name, address and postcode; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying your qualifications and experience, and your right to work in the United Kingdom; curriculum vitae and photograph; employment details and preferences; links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website.

How we collect this information

The information we collect about you will be provided by you, either by applying to one of our adverts via our website or job board, or by corresponding with us by phone, e-mail or otherwise. It will also include information you provide when you register to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, and when you report a problem with our site.

We may also obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and any relevant social media sites. In this case – and within 30 days of collecting – we will inform you that we hold this personal data, the source the data originated from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

Our legal basis for processing data

TWX Recruitment needs to process data to take steps, at your request, prior to entering into a contract with you, and again if we do enter into a contract with you.

Sometimes we need to process data to ensure that we are complying with legal obligations, for example, we are required to check an applicant’s eligibility to work in the UK prior to any employment starting.

We have a legitimate interest in processing personal data during the recruitment process and keeping records of that process. By processing data from job applicants, we can manage recruitment processes, assess and confirm your suitability for employment and make decisions on job offers.  There are times when we may need to process data from job applicants in the response to and defence of any legal claims which may be brought.

We have assessed and believe that in addition to our interests, it is in your interests for us to retain your personal information in relation to any suitable future employment opportunities which you may be interested in.  If you object to us retaining your information you can object by writing to the Managing Director.

Where necessary, we also process health information if we need to make reasonable adjustments to the recruitment process in relation to any type of ill health or disability which an applicant may have.  This allows us to carry out our obligations and exercise specific rights in relation to employment.

We also may request explicit consent to process some special category data such as information about ethnic origin, sexual orientation, health or religion or belief. This information is for equal opportunities monitoring only and you can freely decide whether or not to provide it.  If you choose not to provide this information you will suffer no detriment as a consequence.

For some roles, our Company is obliged to seek information about criminal convictions and offences.  Where we do this, it is only because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

Who has access to your data

Your information will be shared for the purpose of the recruitment exercise, this includes sharing with members of the HR and recruitment team including the recruitment team of any third party Company who has the vacancy, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to any of the data is necessary for the performance of their roles.

We may transfer your personal information outside the EEA. If we do, TWX Recruitment requires the same security measures and safeguards to be in place as when data is transferred within the UK and you can expect continued protection of your personal information.

Where we store your personal data

The data we collect will be stored in various places, including on your application record, in HR files, our recruitment software and on other IT systems (including email).

All information stored on our recruitment software is secured through the Microsoft Azure Infrastructure and located at two data centres locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here.

How long we keep your data for

We retain different types of data for differing periods of time. The criteria we use to determine whether we should retain your personal data and how long for includes:

  • The nature of the personal data
  • Its perceived accuracy of your date
  • Your engagement levels with our services
  • Our legal obligations following an offer or when a placement has been made.

We may archive part or all of your personal data, or retain it on our financial systems but delete all or part of it from our recruitment software system. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database, unless you have requested us to do so.

Our current retention period for data on candidates who have not been placed, or are no longer showing any signs of engagement with our Company, is 12 months.

Your rights

The GDPR provides you with the following rights;

  • The right to be informed about the personal data we process on you
  • The right of access to the personal data we process on you
  • The right to rectification of your personal data
  • The right to erasure of your personal data in certain circumstances
  • The right to restrict processing of your personal data
  • The right to data portability in certain circumstances
  • The right to object to the processing of your personal data
  • The right not to be subjected to automated decision-making and profiling.

If you would like to exercise any of these rights please contact Paul Turner, Managing Director.  You can also contact this person to request a Subject Access Request Form (SAR) if you wish to make a SAR.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (ICO).

Changes to our privacy notice

Any changes we make to our privacy notice in future will be posted on this page and, where appropriate, you will be notified by e-mail. Please check back frequently to view any updates or changes to our privacy notice or for any further information please email

Do we use automated decision making

Our recruitment processes are not based solely on automated decision-making