Privacy Policy

What is the purpose of this document?

Lendable Operations Ltd (“Lendable”) is a "controller" in relation to personal data. 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 UK General Data Protection Regulation (“UK GDPR”).

Data protection principles

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;

  • and 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 but not limited to: name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications;

  • any information you provide to us during an interview; and

  • any other information or test results included as part of the application process.

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

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;

  • information about your health, including any medical condition, health and sickness records; and

  • information about criminal convictions and offences.

Purpose and lawfulness of processing

The purpose of the collecting and processing of your personal data is to manage the process of recruiting for the role for which you have applied.

The lawful basis of the processing of your personal data is explicit consent obtained from you as a candidate to simplify and facilitate recruitment for the role that you have applied for.

How is your personal information collected?

We collect personal information about candidates from the following sources:

  • you, the candidate when you make an application to us;

  • recruitment agencies who submit an application on your behalf;

  • background check provider(s);

  • credit reference agencies;

  • the Disclosure and Barring Service in respect of criminal conviction;

  • any referees you nominate;

  • and in some cases, existing employees can make recommendations about you as a potential applicant. Such employees will add personal data about you as a potential applicant.

How we will use information about you

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

  • assess your skills, qualifications, and suitability for the role you applied for;

  • carry out background and reference checks, where applicable;

  • communicate with you about the recruitment process;

  • keep records related to our hiring processes; and

  • comply with legal or regulatory requirements.

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 covering letter and/or your application form, and the results from any assessments you took as part of our recruitment process, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role.

If you do meet those requirements, we will decide whether your application is strong enough to invite you for an interview. 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 the role. If we decide to offer you the role, we will then request references and we may carry out a criminal record and/or any other recruitment-related check which are specific to the role before confirming your appointment to the role.

If you fail to provide personal information

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. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

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; and

  • we may 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.

Information about criminal convictions

We envisage that we will process information about criminal convictions.

Depending on the role you applied for, we will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We carry out criminal records checks in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

  • we may be legally required by a regulatory body to carry out criminal record checks for the role being applied for;

  • the role being applied for may be one which is eligible for a standard or enhanced check from the Disclosure and Barring Service; and

  • the role being applied for requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.

  • We have in place appropriate safeguards which we are required by law to maintain when processing such data.

We have in place appropriate safeguards which we are required by law to maintain when processing such data.

Automated decision-making

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

Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with the following third parties for the purposes of processing your application:

  • Lever, a recruitment application tracking system which we use to assist us in managing interactions with candidates in the course of the recruitment process;

  • any recruitment agencies we have engaged to assist us with finding a candidate for the position we have advertised;

  • any other contractors and sub-contractors, acting as our processors and sub-processors in accordance with our instructions, for the provision of the recruitment service;

  • authorities or legal advisers in case criminal or improper behaviour is suspected, and authorities, legal advisers, or any other law enforcement agency, if required by us according to law and/or regulation.

All our third-party service providers and other entities in the group 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.

Transferring information outside the UK

We may need to transfer the personal information we collect about you to countries outside either the UK or the European Economic Area (“EEA”), whose personal data protection laws are less strict than in the UK or the EEA. Where we or one of our service providers do so, we will make sure suitable safeguards are in place to protect your personal data, in line with data protection law. The safeguards we use will depend on the circumstances and the third party to which we transfer data, but include entering into an International Data Transfer Agreement, or an International Data Transfer Addendum to the standard contractual clauses issued by the European Commission under the EU GDPR on 04 June 2021.

How we work with Fraud Prevention Agencies

The personal information we have collected from you may be shared with Cifas who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct.

If any of these are detected you could be refused employment. Your personal information will also be used to verify your identity. Further details of how your information will be used by us and Cifas, and your data protection rights, can be found by clicking the following link: https://www.cifas.org.uk/fpn

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 need to know that information for the purpose of performing their obligations to us. 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 the Legal Team.

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.

Data retention

How long will you use my information for?

We will retain your personal information for a period of twelve months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period 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, and to market any other vacancies which may be of interest to you. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Conor McGuire on conor.mcguire@lendable.co.uk.

Right to withdraw consent

When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Conor McGuire on conor.mcguire@lendable.co.uk.

Data protection officer

We have appointed a data protection officer (“DPO”) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) which is responsible for data protection issues in the UK.