Job Application Privacy Policy

Introduction

At Apodi we take your data privacy seriously and are committed to protecting the privacy and security of your personal information. Apodi has registered with the Information Commissioner’s Office, registration numbers: Apodi Limited (Z1114021) and Apodi Healthcare Limited (ZA001657).

This privacy notice describes how we collect and use personal information about you during the recruitment process with us, in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). Where this notice refers to ‘Apodi’, it covers both Apodi Limited and Apodi Healthcare Limited.

As part of our recruitment process, we collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information does Apodi collect?

We collect a range of information about you. This includes:

Your name, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history;
information about your current level of remuneration, including benefit entitlements;
whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process; and
information about your entitlement to work in the UK.

We may collect this information in a variety of ways. For example, data might be contained in application forms and CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests and psychometric data. We record the interview and make use of the transcription function, with your consent. Your choice does not impact on the outcome of the interview process. We may also view publicly available information, such as LinkedIn or other social media platforms.

We may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

For clinical-facing roles, we may request your immunisation records from your GP in line with NHS Employment Standards and Regulations. We will only request this information once a job offer to you has been made and will inform you that we are doing so.

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).

Why does Apodi process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

We may process information about whether applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

For certain roles it may be necessary for the Company to use the Disclosure and Barring Service (DBS) checking service for positions in England and Wales, the Protecting Vulnerable Groups Scheme (PVG) for positions in Scotland, or the AccessNI for positions in Northern Ireland. As a company using these criminal record checking services to help assess the suitability of applicants for positions of trust, Apodi complies fully with its obligations under the Data Protection Act 2018 and UK GDPR pertaining to the safe handling use, storage retention and disposal of certificate information and has a written policy on these matters, which is available to those who wish to see it on request.

If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited. You have the right to withdraw your consent to this at any time (see “Your rights” below).

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Your information may be shared externally to our clients for the purposes of the recruitment exercise. This will include the client recruiting manager.

We will not share your data with third parties (other than our clients or suppliers for the purposes of recruitment and third-party service providers to enable us to use IT/Telecommunications and video conferencing services), unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service (England and Wales), Protecting Vulnerable Groups Scheme (Scotland) or AccessNI (Northern Ireland) to obtain necessary criminal records checks. For clinical-facing roles, we will also share your data with your GP in order to obtain your immunisation records, in line with NHS Employment Standards and Regulations.

We may transfer your data to countries outside the UK and European Economic Area to enable us to undertake the recruitment process. In such cases we will ensure there is an adequacy decision by the Information Commissioner’s Office (ICO) or European Commission in respect of these countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information. If your personal data is transferred to the USA, we will undertake checks to ensure that the US organization has certified their compliance under the UK extension to the EU-US Data Privacy Framework, and that this includes HR-related data.

How does Apodi protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Further details can be found in our Data Protection Policy which can be provided on request.

To ensure that your personal information receives an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects EU and UK laws on data protection If you require further information about these protective measures, you can contact the Data Protection Officer at the details below.

For how long does Apodi keep data?

If your application for employment is unsuccessful, Apodi will hold your data on file for 24 months after the end of the relevant recruitment process, for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent (see “Your rights” below), your data is deleted or destroyed, unless you re-consent to us retaining your data for a further 24 months.

If your application for employment is successful, personal data gathered during the recruitment process will retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Speculative CV’s

If you send us your CV on a speculative basis, we will acknowledge receipt and let you know whether or not we will retain your information on file for consideration for future employment opportunities (if we do, we will send you a copy of this Job Applicant Privacy Notice).

Your rights

As a data subject, you have several rights. You can:

Access and obtain a copy of your data on request;
require us to change incorrect or incomplete data;
require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing.

If you would like to withdraw your consent to us retaining your data on file, please tell us by emailing unsubscribe@apodi.co.uk

If you would like to exercise any other of the above rights, or make a complaint about how we handled your data in relation to your data protection rights please, contact our Data Protection Officer Lynne Swift by email at: dpo@apodi.co.uk

Data Protection Complaints Procedure

Upon receipt of a data protection complaint, we will:

Verify your identity (we may need to ask you, or the person making a complaint on your behalf, for proof of identity in the form of a passport or photocard driving licence before we can investigate your complaint).
Acknowledge receipt of your complaint by email within 30 days of receipt.
Investigate your complaint without undue delay. We may need to ask you to clarify aspects of your complaint or the outcome you are looking for if these are unclear. We will do this at the earliest opportunity.
Keep you up to date on the timeframes relating to the investigation into your complaint and explain any unavoidable delays should these occur.
Provide you with an outcome to your complaint including what actions we have taken to resolve your complaint and, where appropriate, any actions we have taken as a result. We will normally provide the outcome to your complaint in writing via email but in some cases, it may be more straightforward to resolve your complaint over the telephone.

If you believe that we have not complied with your data protection rights and are not satisfied with the way we have handled your complaint or the outcome, you can complain to the Information Commissioner’s Office. You can find more information about how to do that here: https://ico.org.uk/make-a-complaint/. Please note, that as of 2026, you must engage with us about your data protection complaint and give us the opportunity to resolve it before approaching the Information Commissioner’s Office.

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.