Candidate Privacy Notice

Hofy Ltd, Hofy BV and Hofy Inc  (together “Hofy”) respects your privacy and is committed to protecting your personal data.

Hofy is a "controller" in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. This notice contains information about how and why your personal data will be used if you are applying for work with us (whether as an employee, worker or contractor). It also provides you with certain other information that must be provided under the General Data Protection Regulations (GDPR).

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 way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.


The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
  • Any information you provide to us during an interview.

We may also collect, store and use the following types of more sensitive personal information:

  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.


How is your personal information collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Our authorised third party recruitment agencies, from which we collect information about you including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
  • Depending on the role for which candidates are applying, we may collect additional data on candidates from the following sources, including:
    - Our authorised background check providers, from which we collect the following categories of data: right to work data.
    - Authorised credit reference agencies, from which we collect the following categories of data: credit checks.
    - You (or the Disclosure and Barring Service) in respect of criminal convictions
    - Your named referees, from whom we collect information about you including their opinions of your performance in previous roles.
    - We may also collect publicly available data from third party recruitment websites such as LinkedIn.


How we will use information about you

We will use the personal information we collect about you for the following purposes:

  • Assess your skills, qualifications, and suitability for a role with us.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter into a contract of employment or engagement with you.

Having received your CV and covering letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role or work. If we decide to offer you the role or work, we will then take up references. We may also carry out a criminal record and/or carry out any other checks (including a credit check) before confirming your appointment.


If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

If you choose to disclose information about your disability status, we will use it to consider whether we need to provide appropriate adjustments during the recruitment process (or in advance of you commencing work).


Information about criminal convictions

We only process information about criminal convictions where we consider that to be necessary for a specific role.

We will collect information about your criminal convictions history if we would like to offer you a role which is conditional on criminal background checks and any other conditions, such as references, being satisfactory. We are entitled to carry out criminal records checks in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, for roles that require a high degree of trust and integrity we may ask you to seek a basic disclosure of your criminal records history.


Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.


Justification for processing

Your personal data has been/will be processed for the purposes of managing Controller’s recruitment related activities, which include setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereto, and as is otherwise needed in the recruitment and hiring processes. Such processing is legally permissible under Art. 6(1)(f) of Regulation (EU) 2016/679 (General Data Protection Regulation) as necessary for the purposes of the legitimate interests pursued by the Controller, which are the solicitation, evaluation, and selection of applicants for employment.


Data sharing:

Why might you share my personal information with third parties?

We will only share your personal information with our approved third parties for the purposes of processing your application. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.


Approved Third Parties

Hofy uses a third party service provider, Greenhouse Software, Inc to process candidate personal data.  All candidate personal data controlled by Hofy is shared with Greenhouse Software, Inc.  Greenhouse Software, Inc is a cloud services provider located in the United States of America and is engaged by Controller to help manage its recruitment and hiring process on Controller’s behalf.

Hofy candidate data is stored by Greenhouse in Germany.  Accordingly, candidate personal data will be transferred to Germany, which is a jurisdiction offering adequate protection for personal data collected from EU data subjects. 


Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties 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.

Data retention:

How long will you use my information for?

We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you. 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 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.

Rights of access, correction, erasure, and restriction:

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Verity Sayers in writing.


Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, Verity Sayers, by writing to Hofy Ltd, c/o Taylor Wessing, 5 New Street Square, London, EC4A 3BF. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) who is responsible for data protection issues in the UK.