Privacy Policy
Revision: 1-5 Revision Date: 15/11/2023
This Privacy Policy explains how we use your personal information in relation to the Applied online recruitment platform ("Platform"). We really value your trust and your privacy is important to us, so we’ll keep your information secure and manage it in accordance with our legal responsibilities. By providing us with your personal information, you agree to it being used and disclosed in the manner set out in this Policy. If you provide us with your details through our business website (for example, to request a demo) and don’t work for one of our customers, this policy does not apply to you; please instead see our Privacy Policy for website visitors.
So you can understand what this all means in practice we’ve tried to present this policy in clear language without too much “legal jargon”.
We also want to make it easy for you to quickly find answers to the questions that are most important and relevant to you so we’ve split the policy into three sections:
- Section 1: The bits relevant to people applying for a job ("Applicants");
- Section 2: The bits relevant to employers who are offering jobs (“Hiring Managers”); and
- Section 3: The bits relevant to everyone.
We’ve also included some signposts down the side to guide you in the right direction. We hope this is helpful!
Applied is a trading name of Be Applied Ltd ("we", "us").
Of course, you don’t have to provide your personal information to us, but if you don’t you may not be able to fully benefit from all the services that we can offer through the Platform.
Where we refer to "data controller" or "data processor", we give those terms the meanings they have in the Data Protection Act 2018 (or any legislation which updates or replaces this legislation).
Our nominated representative for data protection matters is our Data Protection Officer, who you can contact at DPO@beapplied.com.
Section 1 - Applicants
What personal information do we collect?
Information we collect directly from you
Information to enable you to apply for jobs: We collect the personal information we need in order for you to apply for jobs on the Platform which are being advertised on behalf of Hiring Managers. This may include:
- Full name;
- Date of birth;
- Contact details (email address, telephone number, postal address);
- Employment history;
- Education / qualifications;
- Details of experiences and achievements;
- Responses to questions we put to you to obtain equal opportunities data;
- Responses to skill, work and competency questions; and
- Responses to personality questions and aptitude tests.
The Hiring Manager may want to collect some or all of this information by asking you to upload a CV.
We will ask you to provide information relating to protected characteristics, such as your gender, ethnicity, age range, disability status or sexuality. Providing this information is entirely optional, and you do so freely. Unless you are successful in your application for the role and give your consent to sharing the information with the hiring company, this information is always anonymised and used solely for statistical and research purposes.
Under specific circumstances and where permitted by law, we may process criminal record data under the conditions provided in Schedule 1 of the Data Protection Act 2018. We will only process this data in a lawful and fair manner, and we will take appropriate security measures to protect it. We will never share the data with any third parties. We will not keep this data for any longer than necessary and will securely dispose of it once it is no longer needed.
Registration Information: You will also be asked to set up a user account which will allow you to log into and out of the Platform. You may need to register a username and password to gain secure access to your account.
Other data you intentionally share: We may collect personal data if you submit it to us in other contexts. For example, if you provide us with a testimonial.
Information we automatically collect about you
Like many website operators, each time you visit the Platform we may automatically collect the following information:
Technical information: including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit: including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Information we receive from others:
Referral data: if you arrive on the Platform from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
Performance Data: if you have agreed to it, and you are hired for the role you’ve applied for, we will receive from your new employer data regarding your performance in your role. This will comprise a 1-5 rating from various skills needed for your role and an overall performance rating, and details of any promotions or awards you may have earned in your role.
How do we use your personal information?
Generally, we use your personal information: (i) to process job applications which you make through the Platform, and provide employee performance analysis services to our customers. We do this as a data processor on behalf of the Hiring Managers who are the data controllers. (ii) when (with your consent) employers use the Applied platform to contact you in relation to future roles they wish to notify you of. We do this as data processor; (iii) for research purposes, to help test and improve the service we offer through the Platform, to help Hiring Managers make recruitment better for good, and (iv) to let you know about other hiring opportunities you might be interested in. We do items (iii) and (iv) as a data controller.
As part of our services we may reach out directly to candidates who have opted in to be contacted about other jobs on our Platform, where this is the case, we do this as a data controller. This means we determine the purpose and means of processing personal data. You may also sign up to this service via [https://spotlight.beapplied.com/].
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others, or have your permission to do so. Some more detailed information about the above activities is listed below.
1. Providing services to our customers – allowing you to complete applications for a role, and providing employee performance analysis and other services
When you complete an application for a role on the Platform, we pass some of that information supplied to the Hiring Manager who has invited you to apply for that role. Some of the data will be passed to them only if you are successful in your application, or if they wish to interview you. We may pass them any of the information you provide to us (except for the equal opportunity data, which we will only pass them if you are specifically OK with this) and some of that data may be referred back to in future hiring rounds. If you have consented to be contacted by them directly in respect of future roles, the employer to whom you have made an application using Applied may use our service in order to contact you by email. The employer’s use of your email address will be subject to their Privacy Policy which will be notified to you when we ask you on their behalf for this consent. The Hiring Manager will be responsible for reviewing and responding to the information supplied and otherwise deciding how to proceed with your application. You understand that this means we pass information supplied on to them and that you may receive further direct correspondence from them about the application.
If you have agreed to it, we will on behalf of your employer also process your Performance Data, and your responses to skill, work and competency questions in your job application, in order to provide the employer with employee performance analysis services. The employer will provide us with the Performance Data, and we will use it on their behalf alongside your responses to skill, work and competency questions in your job application to help them assess and analyse their employee performance data as a whole.
If you have agreed to it, we will aggregate your equal opportunities data with that of other applicants for the role you’ve applied for, in order to generate a statistical report for the employer of applicants at different stages of the application process. To be clear, these reports will not identify you individually.
We do all this as a data processor on behalf of your employer who is the data controller. You should refer to the relevant employer privacy policy and applicable recruitment policies or related terms for specific information relating to the application process and details about how they intend to use personal details contained within your application, and your Performance Data.
Where we act as a Processor for the services to our Customers on our Platform and our Customer may wish to contact you for a role, the Customer has the responsibility of obtaining the necessary consent from you where applicable laws apply to communicate with you i.e. for the purposes of direct marketing through electronic means.
2. Research to help make recruitment better, for good.
If you have agreed to it, we will process your Performance Data and your responses to skill, work and competency questions in your job application in order to help us determine how effective Applied is as a tool in helping employers select high-quality employees. We will use this to report our findings to your employer. We may also share our findings publicly, but this will be on a statistical, aggregated basis and you will not be identified or identifiable.
When you sign up, we ask for your consent to use the information you provide to support our recruitment research programme. This improves the service we offer through the Platform.
We are a social purpose company, with a mission to support research into behavioural sciences, including talent analytics and sometimes your information will be used to support our wider research in these areas.
Whenever we publish or publicise findings based on your personal information, those findings will be anonymised so that you cannot be individually identified.
If you agree to support the research programme, we will store a copy of your personal information securely in accordance with this Policy, solely for the purposes of carrying out research. This will be conducted by our hand-selected team of trained scientists, academics and researchers, and sometimes by trusted and carefully selected third parties.
You may withdraw your consent at any time by contacting us using the details set out below.
3. To manage and improve our services to you and the features of the Platform
We internally perform statistical and other analysis on information we collect on the Platform (including usage data, device data, referral data and question and response data) to analyse and measure Applicants’ behaviour and to understand how Applicants use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features.
We may also use your information: (i) for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement and research and development purposes; (ii) for our internal purposes to create and provide new services, features or content. In relation to metadata, we may look at statistics like response rates, question and answer word counts, and publish interesting observations about these for informational or research purposes. When we do this, neither Applicants nor Hiring Managers will be identified or identifiable unless we have obtained their permission; or (iii) to send you notifications about roles similar to the ones you have applied for or we think you might be interested in, or if you are successful, to learn about your experience in the role. You can opt-out of these emails at any time by clicking on the link provided in the email.
4. To contact you about your account
We occasionally send you communications of a transactional nature (e.g. service-related announcements, sending you an email including a link to the page containing an application you have started, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications as they are needed to provide our services to you.
5. To send you the Applied Newsletter, other resources or details of other interesting roles
If you’ve signed up to our Newsletter or online resources we’ll occasionally send you emails so you can stay tuned on the latest research developments in how to make recruitment better, for good! We may also send you updates by email on new roles we think might interest you, if you agree. You can opt-out of receiving the Newsletter, online resources or new role updates at any time by clicking on the link provided in the email. We use profiling and screening techniques to increase the chance that any roles we notify you of by email are relevant to you.
How long do we keep your personal information for?
We keep your personal information to process your role applications, manage your user account, where relevant, to carry out our research and to manage and improve our services to you, and in accordance with legal, tax and accounting requirements.
For product improvements and research purposes, we retain your application and account information for up to seven years after our last interaction. Where your information is no longer required, we will ensure it is disposed of in a secure manner and, where required by applicable law we will notify you when such information has been disposed of.
Section 2 - Hiring managers
What personal information do we collect?
Information we collect directly from you
Information to provide services: We collect the personal information we need to offer you our services and manage our relationship with you, or the business you work for, as our customer.
This may include some or all of the following:
- Full name;
- Work contact details (email address, phone number, postal address); and
- Job title / role.
Registration information: You will also be asked to set up a user account which will allow you to log into and out of the Platform. You need to register a username and password to gain secure access to your account.
Other data you intentionally share: We may collect personal data if you submit it to us in other contexts. For example, if you provide us with a testimonial.
Billing information: If you make a payment to Applied, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder.
Payments are processed in partnership with a third party provider, Stripe Payments UK Limited. Their privacy policy is available at https://stripe.com/gb/privacy. We do not collect or process your credit or debit card details. These are however collected and processed by Stripe. Both we and Stripe comply with applicable PCI standards.
Information we automatically collect about you
Like many website operators, each time you visit the Platform we may automatically collect the following information:
Technical information: including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit: including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Referral data: If you arrive on the Platform from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
How do we use your personal information?
Generally, we use your personal information to create your customer account, to communicate with you about the roles you advertise on the Platform, and to contact you regarding changes or updates to the services we provide.
We may also contact you to provide you with information about our products and services, and those of carefully selected third parties, in each case where we have your prior consent. You can opt-out of receiving these communications by contacting us directly, or by using the link provided in our emails.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others, or have your permission to do so. Some more detailed information about the above activities is listed below.
1. To manage and improve our services to you and the features of the Platform
We internally perform statistical and other analysis on information we collect on the Platform (including usage data, device data, referral data and question and response data) to understand how Hiring Managers use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features.
We may also use your information: (i) for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement and research and development purposes; or (ii) for our internal purposes to create and provide new services, features or content. In relation to metadata, we may look at statistics like response rates, question and answer word counts, and publish interesting observations about these for informational or research purposes. When we do this, neither Applicants nor Hiring Managers will be identified or identifiable unless we have obtained their permission.; or (iii) to contact you regarding your experience using the platform and the performance of candidates that have been hired, as a means of improving our service to you.
2. To contact you about your account
We occasionally send you communications of a transactional nature (e.g. service-related announcements, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications as they are needed to provide our services to you.
3. To send you the Applied Newsletter, if you have signed up for it
If you’ve signed up to our Newsletter or online resources we’ll occasionally send you emails so you can stay tuned on the latest research developments in how to make recruitment better for good! You can opt-out of receiving the Newsletter or online resources at any time by clicking on the link provided in the email.
How long do we keep your personal information for?
We keep your personal information for as long as required to deliver our services to you, where relevant, to manage and improve our services, operate our business, and in accordance with legal, tax and accounting requirements.
Where your information is no longer required, we will ensure it is disposed of in a secure manner and, where required by applicable law we will notify you when such information has been disposed of.
Section 3 - Everyone
Keeping your information secure
We are committed to handling your personal information and data with integrity and care and invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based platform can be 100% secure and so there is always a risk of unauthorised or unintended access to your personal data by third parties that is beyond our control.
Who else do we provide your personal information to?
If you use Applied to apply for a role, we need to share your personal information with the Hiring Managers who work for the employer which has advertised the job you have applied for. If the Hiring Managers direct us to, this might include sharing it with external systems they use as part of their hiring process (an example might be their employee on-boarding system, or their preferred video interview service provider). We will also provide them information benchmarking you against others in relation to your Performance Data, if you have agreed to it. Where you have used Applied to submit an application for one of their roles and consented to them contacting you by email about future roles, we will permit employers to use the Applied platform to email you.
We may also provide your information to others:
In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or shares.
You understand that we may disclose or share personal information with third parties as outlined above. If you are concerned about these arrangements, please feel free to contact us using the details listed at the bottom of this statement.
We may engage outside assistance to help us with research and data analysis; we keep the data shared to a minimum and oblige those providing this assistance to only use it for the purposes of providing that assistance.
We may provide your information to our service providers, who process information on our behalf to help deliver the Platform, for example hosting services and email service providers. These include the following:
Mailchimp provides assistance in relation to our email newsletter and marketing activities. For more information please see here - https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts)
Amazon Web Services (AWS) hosts our applicant and hirer databases on its servers, some of which are in the USA. For more information please see here - https://aws.amazon.com/blogs/security/aws-and-eu-data-transfers-strengthened-commitments-to-protect-customer-data/
Google, which hosts our corporate servers on which we hold account and billing data. For more information please see here - https://cloud.google.com/security/gdpr#tab7
Zendesk is our customer support tool, enabling us to support you if you have questions you need help with. For more information please see here - https://www.zendesk.co.uk/company/customers-partners/eu-data-protection/
Heap is a user behavioural analytics product and service which allows us to collect and analyse data about how our users are interacting with our services. For more information please see here - https://heap.io/blog/heaps-commitment-to-gdpr-and-data-privacy
Datadog, which tracks, troubleshoots and optimises the way the Platform works. For more information please see here - https://www.datadoghq.com/legal/privacy/
Transloadit, which we use to enable applicants to upload CVs. For more information please see here - https://transloadit.com/legal/privacy/
Slack, a tool we use to communicate as a team and it also allows us to notify clients of key events in their hiring cycle. For more information please see here - https://slack.com/intl/en-gb/trust/privacy/privacy-policy?geocode=en-gb
Close, a tool we use to contact candidates who have opted-in to hear about other job opportunities from Applied (as the data controller). For more information, please see here - https://www.close.com/gdpr
We take steps to ensure that third parties who have access to your personal information treat it with the same consideration that we do. For more information on where these organisations may process your data see below.
Legal enforcement bodies: We may from time to time be required to disclose information about you to law enforcement bodies, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
For protective purposes: We may need to share your data with others in order to protect our rights, users, systems, and services.
We may also share it with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
Storage and transfer of your personal data
Your information may be transferred to, stored at or processed by, organisations located in other countries around the world. For example, to allow the processing of payment details you provide or the provision of support services to help us deliver the Platform.
As privacy laws in other countries may not be equivalent to those in your home country, we only make arrangements to transfer data overseas where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it is given in your home country.
Certain of our service providers are based outside the UK (including in the USA) so their processing of your personal data will involve a transfer of data outside the UK. They include the following (more details on our use of each of the providers listed is set out in the “Who else do we provide your personal information to?” section above.
Amazon Web Services (AWS)
Mailchimp
Zendesk
Heap
Datadog
Slack
With the above service providers, we have specific contracts approved for use in the UK which give personal data the same level of protection it has in the UK. For further details, see here.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Information about others
If you provide us with information about other individuals, for example details of a referee or colleague, you must check that they agree to you providing us with their details. Tip: Keep a record of their agreement and provide them with a copy of, or link to, this Policy to avoid any concern.
Other people’s websites
The Platform may contain links to and from websites operated by other people, including Hiring Managers. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We don’t accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Updating your account and preferences
If you register a user account with us please do keep your details up to date and notify us of any changes to the personal information. You can do this through your account login or by emailing hello@beapplied.com.
Cookies
The Platform uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, beyond how it is explained in sections above, feel free to contact us at hello@beapplied.com.
Your rights to your information
You have the following rights:
- The right to request details of the information we have about you (this is subject to some limitations, for example where meeting your request involves disclosing someone else’s information).
- The right to withdraw your consent to the use of your information where we are relying on that consent (for example, you can opt out of receiving our Newsletter). We may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.
- In some circumstances, you have the right to receive some of your information in a usable format. This right only applies to information which you have provided to us.
- The right to ask that we update your information if it is inaccurate or incomplete.
- The right to ask that we erase your information in certain circumstances. There may be circumstances where you ask us to erase your information, but we are legally entitled to retain it.
- The right to request that we restrict the processing of your information in certain circumstances. In others, we will be legally entitled to refuse that request.
- If you want to take any of the above actions please contact us via hello@beapplied.com or write to Privacy, Be Applied Ltd, Covent Garden, 71-75 Shelton Street, London, WC2H 9JQ, UK and we will respond to your requests as soon as we reasonably can, but within any legally mandated timeframes.
In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your personal information. If this is the case we’ll tell you the reasons why.
If your request for access to your information relates to the use of your personal information in the context of your job application (as opposed to our use of your information for research or to communicate with you), you should contact the relevant Hiring Manager directly.
What is the legal basis on which we rely to process personal information?
For some uses, we may process personal information with consent (for example, when you decide to give us answers to optional questions to derive equal opportunities data, or agree to receive our newsletter). You have the right to withdraw your consent at any time by contacting us on the email address below.
On other occasions, we may process personal information when we need to do this to fulfil a contract (for example, for billing purposes) or where we are required to do this by law. If we didn’t process the data for those purposes, we’d be unable to provide you with the Applied service.
We also process your personal information when it is in our legitimate interests to do this and when we consider these interests are not overridden by your data protection rights. Those legitimate interests include using your information for research and analysis purposes, which we aim to do in a way that works to improve the recruitment process for both hirers and applicants. We also rely on legitimate interests when we process your Performance Data for the purposes of producing stats to determine and promote Applied’s effectiveness as a recruitment tool.
Information Commissioner’s Office
You have the right to complain to the Information Commissioner's Office (ICO) if you believe we have not handled your request in an appropriate manner. For information on contacting the ICO please see their website (https://ico.org.uk/concerns/).
Updates
We keep this Policy under regular review and may update it from time to time but if we do this we will publish the changes on the Platform, and (if the change is an important one) we may email you to let you know. So please check this policy regularly for changes. If you do not accept the amended Policy, please stop using the Platform.
Any Questions – Contact us!
If you have any questions about this Policy, or would like to exercise your rights with respect to your personal information, please contact us via DPO@beapplied.com or write to Privacy, Be Applied Ltd, Covent Garden, 71-75 Shelton Street, London, WC2H 9JQ, UK.
Instant EU GDPR Representative Ltd is the EU representative in the EEA. Instant EU GDPR Representative Ltd is registered in Ireland with its office located at Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland. Contact is DPO@beapplied.com.