Privacy Policy


We at Distinctive People are committed to protecting the privacy of our job applicants, candidates, clients and suppliers; being transparent about how we collect and use personal data; and in meeting our data protection obligations.

This policy covers the core information required under the General Data Protection Regulations ((EU) 2016/679). It sets out how and why your personal data will be used, namely for the purposes of Recruitment, HR and OD services, and how long it will usually be retained for. The policy applies to all job applicants, candidates, suppliers and clients accessing our services.

Distinctive People Ltd (Company Registration Number 09838681) is the Data Controller and our Data Protection Officer is Mark Glinwood. We can be contacted on 0203 887 0663 or


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 other way
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and up to date
  • Kept securely and only as long as necessary for the purposes we have told you about


What personal data do we collect about you?

We collect and use only the information necessary for us to carry out our recruitment processes effectively, and to assess your eligibility through the different stages of recruitment. This includes:

  • The information you have provided to us in your application form, CV and covering letter and as requested in our Recruitment Packs. This includes name, title, address, telephone number and personal email address; educational background and qualifications; details of your skills, experience and employment history; details about current salary, benefits and notice period; reference details and details about your identity/entitlement to work in the UK. We may also ask you about information on any employment restrictions and/or links to us and our clients.
  • Any information you provide to us during an interview with us or our client
  • The results of any assessments or tests carried out as part of the recruitment process
  • Interview and assessment reports on your assessment and testing outcomes

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Equal opportunities monitoring information, including information about your gender, age, race or ethnicity origin, sexual orientation, health, disabilities and religion or belief
  • Information about any criminal convictions

We will only collect sensitive personal data from you, and further process this data, where you have given your explicit consent


Why do we collect personal data?

The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.

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


How is your personal data collected?

We may collect this information from a number of sources, including:

  • Shared by you, for example, as part of an application form, CV or covering letter
  • Collected through conversations, interviews or other forms of assessment, including online tests
  • Obtained from your passport or other identity documents
  • Through references supplied by former employers
  • From an agency or third party acting on your behalf
  • Information from employment background check providers
  • Information from criminal records checks
  • Through publicly available sources, such as Social Media
  • Through word of mouth

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).


How do we use your personal data?

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

  • Notify you about suitable roles and opportunities
  • Assess your skills, qualifications, and suitability for the work or role
    • Carry out background and reference checks, where applicable
    • Communicate with you about the recruitment process
    • Keep records related to our recruitment processes
    • Manage any interim engagements or placements with a client
    • Collate relevant monitoring information
    • Comply with legal or regulatory requirements
    • Promote or market our services, and potential future opportunities


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, beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.


Automated decision making

We do not use automated decision making in any part of our recruitment process.


How long do we keep your personal data for?

We will only retain your information for as long as is necessary for us to use your information as described above, or to comply with our legal obligations

We will retain your personal information for a period of 6 months after we have communicated to you our client’s 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. After this period, we will securely destroy your personal information in accordance with our data retention procedure and applicable laws and regulations.

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.


Who do we share your personal data with?

We will only share your personal information with third parties, such as our clients or suppliers, for the purposes of processing your application and carrying out recruitment processes.

All our third-party clients or suppliers are required to take appropriate security measures to protect your personal information in line with our policies. We only permit our clients or suppliers to process your personal data for specified purposes and in accordance with our instructions.

Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal information may involve a transfer of information outside the EEA. We do not share your personal information with third parties unless we are required to do so by law or where you have consented to us sharing your information. We may share your personal information with certain trusted third parties in accordance with certain contractual obligations that we have with them and to assist us in providing you with our services, including: IT service and cloud-based storage providers.

The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will take reasonable steps to implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.


What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us 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.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information


How do we safeguard your personal data?

We take the security of your data very seriously and have put in place appropriate measures that are designed to prevent unauthorised access to or misuse of your personal data.

In addition, we limit access to your personal information to those employees, and third-party clients or suppliers 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.

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.


What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data:

  • The right to be informed – You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.
  • The right of access – You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
  • The right to rectification – You are entitled to have your information corrected if it’s inaccurate or incomplete.
  • The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  • The right to restrict processing – You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
  • The right to data portability – You have rights to obtain and reuse your personal data for your own purposes across different services.
  • The right to object to processing – You have the right to object to certain types of processing, including processing for direct marketing.
  • The right to lodge a complaint – You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
  • The right to withdraw consent – If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

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

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

Further Policies:

Distinctive People Data Protection Policy

DP Data Protection Policy – Final

Job Applicant Privacy Notice: 

Job Applicant Privacy Notice – Final