Privacy Policy
Who we are and how we use your information
The 3173 Company Limited (“3173”, “we”, “us”, “our”) with a registered address at Linen Loft, 27–37 Adelaide Street, Belfast, Northern Ireland, BT2 8FE, is committed to protecting and respecting your privacy. This Recruitment Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.
For the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018 (together, “GDPR”), The 3173 Company Limited is the Data Controller.
Where you apply for an opportunity posted by us, this Recruitment Data Privacy Notice applies in addition to our general Privacy Notice, which is available on our website
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. Pinpoint processes personal information as a data processor on our behalf and is only entitled to process your personal data in accordance with our instructions.
We use OMNI RMS, a third-party recruitment service, to assist with our recruitment process. OMNI process personal information on behalf of 3173 and is only entitled to process your personal data in accordance with our instructions.
What personal information we collect
Information we collect from you
We collect and process some or all of the following types of information from you:
- Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method.
- Personal details such as name, email address, postal address, date of birth, and contact telephone numbers.
- Information about your qualifications, experience and employment history, including skills and experience that you provide to us.
- Professional information such as your CV/résumé, work history, education, skills, qualifications, and LinkedIn or other professional profiles.
- Information you provide during interviews or assessments, and any other information you choose to share during the recruitment process.
- If you contact us, we may keep a record of that correspondence.
- Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.
- Tags and preferences we record to understand your areas of interest (e.g. locations, departments, seniority level, role types).
Information we collect from other sources
We may also obtain information about you from other sources:
We may also obtain information about you from other sources:
- Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
- Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way, we obtain your personal data from these sources.
Special category and criminal records data
We process special category data only where necessary for:
We process special category data only where necessary for:
- Employment and equality law obligations,
- The assessment of your working capacity by a health professional, and/or
- Establishing, exercising or defending legal claims
(Article 9(2)(b)/(h)/(f) GDPR and DPA 2018 Schedule 1).
Our roles require Basic Screening checks, such as DBS Standard, Disclosure Scotland or Access NI, dependant on location, we process criminal offence data only where permitted by law and in accordance with applicable DPA 2018 Schedule 1 conditions. We maintain restricted access to this information and apply the appropriate retention schedules for this data.
How and why we use your personal information
Lawful basis for processing
We rely primarily on legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interest is the recruitment of staff for our business.
We rely primarily on legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interest is the recruitment of staff for our business.
In some cases, we may also rely on:
- Legal obligations (for example, where we must check a successful candidate’s eligibility to work in a particular country), and
- Consent, where you have clearly given it (for example, where required for specific types of communication or where you explicitly ask us to keep your details on file for future opportunities).
Purposes of processing
We use information held about you in the following ways:
We use information held about you in the following ways:
- To consider your application in respect of a role for which you have applied.
- To consider your application in respect of other roles which may be suitable.
- To communicate with you in respect of the recruitment process.
- To manage interviews, assessments, and other recruitment‑related activities.
- To enhance any information that we receive from you with information obtained from third‑party data providers.
- To find appropriate candidates to fill our job openings.
- To help Pinpoint improve its services (in de‑identified or aggregated form where possible).
SMS / Text Messaging
We may use your mobile phone number to send you text messages (SMS) related to the recruitment process, such as application updates, interview scheduling and onboarding communications. Your mobile phone number and any opt‑in consent you provide for SMS communications will never be shared with or sold to third parties or affiliates for marketing purposes.
We may use your mobile phone number to send you text messages (SMS) related to the recruitment process, such as application updates, interview scheduling and onboarding communications. Your mobile phone number and any opt‑in consent you provide for SMS communications will never be shared with or sold to third parties or affiliates for marketing purposes.
You may opt out of receiving text messages at any time by replying STOP to any message you receive from us.
Automated decision‑making / profiling
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider, based on criteria we have identified. The process of finding suitable candidates is automated; however, any final decision as to who we will engage to fill a job opening will be made by our team, not solely by automated means.
Talent Pooling
We may use Pinpoint’s technology to help us build a talent pool of appropriate candidates for us to consider based on criteria we have identified.
We may use Pinpoint’s technology to help us build a talent pool of appropriate candidates for us to consider based on criteria we have identified.
You, as a candidate, have the option to use the Manage Your Data service to opt out. You are not required to join our talent pool. However, if you choose not to provide certain information, we may not be able to consider you for some opportunities or contact you about roles that may interest you.
How we store and protect your personal data
Security
We take appropriate technical and organisational measures to ensure that all personal data is kept secure, including measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We take appropriate technical and organisational measures to ensure that all personal data is kept secure, including measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data‑security breach. We will notify you and any applicable regulator of a suspected data‑security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means; any transmission is at your own risk.
Where we store your personal data
The data that we collect from you and process using Pinpoint’s services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes.
By submitting your personal data, you agree to this transfer, storing or processing. We ensure that appropriate safeguards are in place for any international transfers of personal data, in line with applicable data‑protection law.
How long we keep your personal data
We retain candidate data for a maximum period of 36 months from the time of application, unless a longer or shorter period is required by law or justified by ongoing recruitment activity.
Your personal information will be deleted on one of the following occurrences:
- Deletion of your personal information by you via the Manage Your Data tool; or
- Receipt of a written request by you to us.
Your rights
Under the GDPR, you have a number of important rights. In summary, these include the right to:
- Access your personal data and certain other supplementary information that this Privacy Notice is already designed to address.
- Require us to correct any mistakes in the information which we hold about you.
- Request the erasure of personal data concerning you in certain situations.
- Request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine‑readable format, and have the right to transmit those data to a third party in certain situations (data portability).
- Object at any time to processing of personal data concerning you for direct‑marketing purposes.
- Object in certain other situations to our continued processing of your personal data, including processing based on our legitimate interests.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- Otherwise restrict our processing of your personal data in certain circumstances.
- Claim compensation for damages caused by our breach of any data‑protection laws.
If you would like to exercise any of these rights, please either:
- Use the Manage Your Data tool provided; or
- Contact us using our contact details below, ensuring we have enough information to identify you, and providing proof of your identity and address and confirmation of which information your request relates to.
Recipients and processors
We may disclose your personal data within our corporate group for HR operations, recruitment and reporting, and to third‑party processors including payroll and benefits providers, pension providers, IT and cloud service providers, occupational health providers, and professional advisers. We also use an engagement survey provider to measure culture and engagement. The provider acts as our processor under an Article 28‑compliant agreement, and we use anonymisation/aggregation wherever feasible. Participation details and any personal responses are processed in accordance with this notice and our internal policy.
International transfers. We may transfer personal data outside the UK. Where we do so, we rely on adequacy regulations or implement appropriate safeguards (e.g. UK IDTA or UK Addendum to the EU SCCs). Further details are available on request.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data‑protection laws occurred. In the UK, this is the Information Commissioner’s Office (ICO). Please contact our Head of Governance, Kirsten Cowdy, at Kirsten.cowdy@3173.co.uk