Privacy Policy - Recruitment
We at BrightLocal manage our employer branding and recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.
In this privacy policy, we explain how we process your personal data if:
You visit our Career Site (you being a “Visitor”)
You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)
You apply for a position with us, via our Career Site or a third party service (you being an ”Applying Candidate”)
We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)
We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)
We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).
This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.
When we use the term “Candidate” in this privacy policy, we are referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it’s stated otherwise.
Contact Details:
Address: First Floor, Huntingdon House, 20-25 North Street, Brighton, BN1 1EB, UK.
Phone: 01273 605027
We have appointed a Data Protection Officer (DPO), who can be contacted should you have any questions regarding the ways in which your data is processed.
DPO email: privacy@brightlocal.com
1. About processing of personal data
Personal data is all information that can be directly or indirectly linked to a living, physical person. Examples of personal data are: name, e-mail address, telephone number and IP address. Processing of personal data means any action performed on personal data, whether this be through automated or manual means. This includes collecting, generating, analyzing, sharing, and deleting personal data.
There are laws and regulations on how companies may process personal data, called data protection laws. Different data protection laws apply to different types of use of personal data, and in different parts of the world. The data protection laws relevant for our use of your personal data, as described in this privacy policy, are the UK General Data Protection Regulation (2016/679, “UK GDPR”) and the Data Protection Act 2018.
Most obligations under the UK GDPR apply to the data controller. A data controller is the entity that decides for which purposes personal data will be processed, and how the processing will be executed. The data controller can use a data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller, and may not use the personal data for its own purposes.
We are the data controller when we process your personal data as described in this Privacy policy.
2. What personal data do we process?
All individuals
Device information - If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
Technical and statistical data - If you visit our Career Site, we will collect technical and statistical data about your use of the site, such as information about which URLs you visit, and your activity on the site.
Communications data - We will collect and store your communication with us, including the information you provided in the communication. This may include the content of emails, video recordings, messages on social media, the information you add to your account with us, surveys, etc.
Contact details - Such as your name, email address, telephone number and physical address.
Candidates
Data from interviews, assessments and other information from the recruitment process - Such as notes from interviews with you, assessments and tests made, salary requirements.
Information in your application - Such as your CV, cover letter, work samples, references, letters of recommendation and education.
Information in your public profile - Meaning the information we collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.
Information provided by references - Meaning the information we receive from our employees or partners who refer you to us, or by the persons you have listed as your references.
3. Where do we receive your personal data from?
All individuals
From the Career Site. If you visit our Career Site, we collect technical and statistical information about how you use the Career Site, and information from your device.
Directly from you. Most of the information we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application or provide you the information you request to get from us.
References
Candidates
From public sources. We may collect personal data about you from public sources, such as LinkedIn or the website of your current employer.
From our references. We may receive information about you from our employees or partners (such as recruitment service providers), when they believe your profile is of interest for our current or future vacancies.
From your references. If you provide us with references, we may collect information about you from them.
Data we create ourselves or in cooperation with you. Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may for example include notes from interviews with you, assessments and tests made.
4. For what purposes do we process your personal data?
Purpose/Activity:
Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.
Type of data:
All the categories of personal data listed above can be used for this purpose.
Lawful basis for processing including legitimate interest:
Legal obligation (Article 6(1)(c)) & Legitimate Interests (Article 6(1)(f)) to establish, exercise, or defend legal claims and protect BrightLocal’s legal position.
Purpose/Activity:
Share your personal data with other recipients, for the purposes mentioned in Section 5 below.
Type of data:
All the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
The lawful basis depends on the underlying purpose for which data was originally collected. Personal data is shared where necessary:
For the performance of a contract (Article 6(1)(b))
To comply with legal obligations (Article 6(1)(c))
For legitimate interests (Article 6(1)(f)) such as operating our recruitment processes and systems.
Purpose/Activity:
Collect information about your use of the career site, using cookies and other tracking technologies, as described in our Cookie Policy.
Type of data:
Device information, technical information, and usage/behavioural data.
Lawful basis for processing including legitimate interest:
Consent (Article 6(1)(a)) for non-essential cookies used to analyse usage and improve the career site
Legitimate Interests (Article 6(1)(f)) for strictly necessary cookies required for site functionality.
Purpose/Activity:
Maintain, develop, test, and otherwise ensure the security of the career site
Type of data:
Device information; Technical and statistical data.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to ensure the security, integrity and proper functioning of the career site.
Purpose/Activity:
Provide you with updates about vacancies with us.
Type of data:
Contact details; Communications data.
Lawful basis for processing including legitimate interest:
Consent (Article 6(1)(a)) where you have opted in to receive job alerts
Legitimate Interests (Article 6(1)(f)) where there is a prior relationship and a reasonable expectation of receiving such communications.
Purpose/Activity:
Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
Type of data:
All the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
Steps prior to entering a contract (Article 6(1)(b)).
Purpose/Activity:
Collect and evaluate your professional profile on our own initiative. This also includes communicating with you regarding your profile.
Type of data:
All the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to identify and engage suitable candidates for current or future roles in proactive sourcing.
Purpose/Activity:
Contact you directly about specific, future vacancies with us.
Type of data:
All the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to inform candidates about relevant opportunities.
Purpose/Activity:
Record the interview(s) with you.
Type of data:
Identity and communications data.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to support accurate record-keeping, fair and consistent assessment of candidates, and internal review of recruitment decisions.
Purpose/Activity:
Contact you to ask for your participation in surveys
Type of data:
All the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to improve recruitment processes and candidate experience through feedback.
Purpose/Activity:
Contact you to ask you to provide information about a candidate, and evaluate the information you provide.
Type of data:
Contact details; Communications data.
Lawful basis for processing including legitimate interest:
Steps prior to entering a contract (Article 6(1)(b))
Purpose/Activity:
AI-assisted candidate information retrieval and recruitment administration.
Type of data:
All of the categories of personal data listed above may be used for this purpose.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) in ensuring efficient administration of recruitment activities and supporting recruiters in reviewing candidate information.
Purpose/Activity:
AI-assisted recruitment screening
We use AI-assisted tools to support with screening CVs against job requirements and producing structured summaries or scorecards. Any AI-generated outputs are reviewed by a human decision-maker, and we do not make recruitment decisions based solely on automated processing.
Type of data:
CVs including identity, contact, employment, and education data.
Lawful basis for processing including legitimate interest:
Legitimate Interests (Article 6(1)(f)) to support an efficient and consistent recruitment process by assisting with the review and evaluation of candidate applications.
5. Whom do we share your personal data with?
Our service providers. We share your personal data with our suppliers who provide services and functionality in our employer branding- and recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.
Our group companies. We share your personal data with our group companies, when they provide us services and functionality to our employer branding- and recruitment process, such as access to particular systems and software.
Companies providing cookies on the Career Site. If you consent to it, cookies are set by other companies than us, who will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in our Cookie Policy.
To authorities and other public actors - when we are ordered to do so. We will share your personal data with authorities and other public actors when we have a legal obligation to do so.
To parties involved in legal proceedings. If needed to protect or defend our rights, we share your personal data with public authorities or with other parties involved in a potential or existing legal proceeding. This can for example be in case of discrimination claims.
Mergers and acquisitions etc. In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business to another company, we may share your personal data to other parties involved in the process.
6. On what legal bases do we process your personal data for recruitment?
To be able to process your personal data, we need to have a lawful basis. A lawful basis is a reason for processing the personal data that is justified under the UK GDPR.
Performance of a contract (or steps prior to entering into a contract)
In most cases, we process your personal data because it is necessary to take steps at your request prior to entering into an employment contract with you. This includes processing such as assessing you application, communicating with you about the role, and progressing your candidacy through the recruitment process.
Legitimate Interests
In some cases, we process your personal data on the basis of our legitimate interests. In particular, we may record interviews or use tools and technologies, including AI-assisted tools to support with the review of applications in an efficient way within our interests. That our interest outweighs your right not to have your data processed for this purpose.
You have the right to object to the processing carried out on this basis, If you do so, we will ensure your application is reviewed without the use of such tools. For more information about how to exercise your rights, see Sections 9 and 10 below.
7. When do we transfer your personal data outside of the EU/EEA, and how do we protect it then?
We always strive to process your personal data within the EU/EEA area.
However, some of our service providers process your personal data outside of the EU/EEA. We also use suppliers whose parent company, or whose subcontractor’s parent company, is based outside the EU/EEA. In these cases, we have taken into account the risk that the personal data may be disclosed to countries outside the EU/EEA, for example because of an authority request.
In cases where another recipient of your personal data (as described in Section 5 above) is based outside the EU/EEA, this will also mean that your personal data is transferred outside the EU/EEA.
When we, or one of our suppliers, transfer your personal data outside the EU/EEA, we will ensure that a safeguard recognized by the GDPR is used to enable the transfer. We use the following safeguards:
Adequacy decisions: The European Commission may determine that a country outside the EU/EEA offers an adequate level of protection. In particular, we rely on:
The EU Commission’s adequacy decision for the United Kingdom, allowing transfers from the EU to the UK without the need for additional safeguards.
The EU-US Data Privacy Framework, including the UK extension (UK-US Data Bridge), for transfers to self-certified organisations in the US.
Where there is no adequacy decision, we enter into the EU Commission’s standard contractual clauses with the recipient of the personal data outside the EU/EEA. For transfers from the UK to third countries, we may also use the UK’s international Data Transfer Addendum (IDTA). This means that the recipient guarantees that the level of protection for your personal data afforded by the GDPR still applies, and that your rights are still protected.
When your personal data is transferred outside the EU/EEA, we also implement appropriate technical and organizational safeguards, to protect the personal data in case of a disclosure. Exactly which protective measures we implement depends on what is technically feasible, and sufficiently effective, for the particular transfer.
If you want more information about the cases in which your personal data is transferred outside the EU/EEA you can contact us using the contact details in Section 9 and 10 below.
8. For how long do we keep your personal data?
All individuals
If we process your personal data for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
We keep your personal data for one (1) year for security purposes. The retention periods for cookies are set out in our Cookie Policy. We keep your personal data to analyse the performance of the Career Site for as long as we keep personal data about you for other purposes.
Candidates
If you are a Connecting Candidate (only), we keep your personal data for as long as you remain connected with us.
For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with us.
If you don’t succeed in the initial recruitment process, we keep your personal data for as long as needed to consider, and potentially contact you, for relevant future job openings.
If you are hired, we will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of.
References
We keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference.
9. What rights do you have, and how can you exercise them?
In this section, you will find information about the rights you have when we process your personal data. As described below, some of the rights only come into play when we process your personal data under a particular legal basis.
If you want to exercise any of the rights listed here, we suggest that you:
Right to be informed
You have the right to be informed about how we process your personal data. You also have the right to be informed if we plan to process your personal data for any purpose other than that for which it was originally collected.
We provide you with such information through this privacy policy, through updates on our Career Site (see also Section 11 below), and by answering any questions you may have for us.
Right to access your personal data
You have the right to know if we process personal data about you, and to receive a copy of the data we process about you. In connection with receiving the copy of your data, you will also receive information about how we process your personal data.
Right to access and to request a transfer of your personal data to another recipient (“data portability”).
You can request a copy of the personal data relating to you that we process for the performance of a contract with you, or based on your consent, in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that we transfer your data directly to another recipient.
Right to have your personal data deleted (“right to be forgotten”)
In some cases, you have the right to have us delete personal data about you. This is for example the case if it’s no longer necessary for us to process the data for the purpose for which we collected it; if you withdraw your consent; if you have objected to the processing and there are no legitimate, overriding justifications for the processing. (For the separate right to object, see below.)
Right to object against our processing of your personal data
You have the right to object to processing of your personal data which is based on our legitimate interest, by referencing your personal circumstances. Where we process your personal data for marketing purposes based on your consent, the right to object is absolute.
Right to restrict processing.
If you believe that the personal data we process about you is inaccurate, that our processing is unlawful, or that we don’t need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. If you object to our processing, as described just above, you can also request us to restrict processing of that personal data while we make our assessment of your request.
When our processing of your personal data is restricted, we will (with the exception of storage) only process the data with your consent or for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons relating to an important public interest.
Right to rectification
You have the right to request that we rectify inaccurate information, and that we complete information about you that you consider incomplete.
Rights in relation to automated decision making and profiling
You can ask us to review any automated decision we have made, where such decisions have a legal or similarly significant effect on you.
Right to withdraw your consent
When we process your personal data based on your consent, you have the right to withdraw that consent at any time. If you do so, we will stop processing your data for the purposes you’ve withdrawn your consent for. However, it doesn’t affect the lawfulness of processing that was based on your consent before it was withdrawn.
Right to raise a complaint
If you are unhappy with how we have processed your personal data and you are based in the UK, you can lodge a complaint with the Information Commissioner’s Office (ICO) here.
If you are based in the EU, you can also lodge a complaint with your national data protection authority. A list of EU supervisory authorities is available here.
10. Where can you turn with comments or questions?
If you want to get in touch with us to exercise your rights, or if you have any questions, comments or concerns about how we handle your personal data, you can reach us by sending an email to privacy@brightlocal.com, or George.denny@brightlocal.com
11. Updates to this Privacy policy
We update this privacy policy when necessary - for example, because we start processing your personal data in a new way, because we want to make the information even clearer to you, or if it’s necessary to do so in order to comply with applicable data protection laws.
We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.
Date of publication: October 2026
