People Privacy Notice

Clear Score Technology Limited (“ClearScore” or “We”) respect your privacy and protecting your information is paramount to us. We want you to be informed and empowered with respect to your privacy when you apply for a position or work with us.

This People Privacy Notice sets out our views and practices regarding your personal data and how we collect, process and treat it. When you make an application for a position with us or accept an employment offer and join us as an employee, or if you join us as a worker or a contractor, your personal data will be processed and handled by us in accordance with this notice.

ClearScore is a data controller, which means we are responsible for deciding how we process the personal data that you provide us with. Our data controller registration number is ZA100119 and our address is Vox Studios, VG 203, 1-45 Durham Street, London, SE11 5JH.

The information we collect

We may collect or process information about you when you apply for a position with us or if you work with us. This information may be provided by you, by our suppliers (such as employment agencies or external recruiters), by your previous employer(s) (in the case of references) and the Disclosure and Barring Services (in the case of criminal checks).

If you are an applicant. The information we collect and process may include:

• Title
• Name
• Address
• Email address
• Date of birth
• Gender
• Telephone number
• Work History (including CV)
• Current employment information
• Your role preferences
• Certificates, portfolios or past projects
• Other information you provide us with

If you choose to disclose such information to us, we may also collect data relating to your health, including any medical condition, for the purposes of offering reasonable adjustments through the recruitment process to ensure equitable participation.

If you work with us. In addition to the above, the information we collect and process may also include:

• Gender
• Nationality
• Results from background and any criminal record checks
• References
• Visa, permit or residence card
• National Insurance Number
• Passport or other identification document
• Communications between you and us and information about your use of our workplace systems
• Medical insurance information
• Salary, pension, employee incentives, student loan and other benefits information
• Your P45 or P60 forms
• Annual leave information
• Banking details
• Emergency contacts
• Photographs
• Reasons for leaving, and any references provided by us
• Gender identity
• Caregiver status
• Parent status

Other special category data (voluntary):

• Ethnicity
• Sexual orientation
• Religion
• Health information

How we use the information

We will use the information you provide us with and the information we receive from other sources to:

• determine if you are suitable for a role with us
• to keep you informed of any prospective roles that may be available
• establish that you have the right to work with us
• conduct criminal background checks as permitted by law
• process payments such as your salary, expenses, reimbursements and other such payments
• offer you work benefits such as a pension plan, medical insurance and other such benefits
• to manage the employment relationship between you and us
• to assess your performance and/or your conduct as an employee
• to communicate with you, or with your emergency contacts
• to promote ClearScore on its website and internal and external facing platforms (including social media)

We will use the “special categories” of personal data for the following purposes:

• to apply as a demographic filter on Culture Amp in order to use for analysis of survey results
• for PPP diversity reporting including hiring, promotions, leavers and seniority
• to monitor equal opportunities and diversity at ClearScore

What we will never do. Rest assured, we will never sell your information to third parties.

Who we may share your data with

We may need to disclose your data to third parties that we work with in order to process your application or manage our relationship with you as your employer. These third parties act on our instructions and are processors of your information.

Subprocessors. We may share your information with the following subprocessors:

Group company. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

What is the legal basis for using this information?

Our lawful basis may include consent (where you have given consent), to perform our obligations under the employment, worker or contractor agreement we have with you, or where we need to comply with a legal obligation.

Consent. For the information that we process if you are an applicant (as outlined above) or if you consent and voluntarily provide any personal data (including special category data) as an applicant, employee, or contractor, we will seek your consent to do so. You have the right to withdraw or decline your consent at any time.

Performance of a contract. We need you to give us the information you provide, and to collect information about you from third parties in order for us manage our employment relationship with you or to conduct work preparatory into entering into a contract with you.

Legal Obligation. We may need to check that you are legally entitled to work in the UK, handle any legal disputes involving you or third parties (including any accidents at work) or to prevent fraud.

How we protect your information

All information you provide to us is stored on our secure servers.

Special category data will be subject to more stringent access controls and will only be shared with the staff required for the fulfilment of the purposes outlined above. Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.

How long we keep your information for

If you are an applicant. We will keep your information for a period of two years, for the purposes of assessing if you are a viable candidate for a role we currently have available or that may be available in the future.

If you work with us. We will keep your information for the duration of any contractual arrangement between you and us (employment, consultancy or otherwise) and for a period of six years after the termination of that contractual arrangement. Special category data will be deleted upon termination of your employment with ClearScore or earlier if you (i) request us to delete such data; or (ii) withdraw your consent to the processing of such data by ClearScore.

Your information may be permanently deleted before the periods set out above in the event we determine it is no longer necessary for the purpose for which it was collected.

Your rights

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

• Correct your data: You will be able to correct some information that we hold about you that is inaccurate or incomplete through various platforms we provide. Where this is not possible, you may contact us directly and request that your information be corrected
• Request access to your data: You can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law.
• Erase your data: You can ask us to fully or partially delete your personal data where there is no compelling reason for us to keep using it. We may continue using your information if such usage is necessary for compliance with our legal obligations
• Download your data or send it to another controller: You can request a copy of the data you provided us with in a machine-readable format, where this is technically feasible. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
• Restrict the use of your data: You have the right to ‘block’ or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your information, but may not use it further.
• Right to withdraw consent: Where you have given your consent for us to use your information, you have the right to withdraw your consent at any time. You may do this by contacting us directly.

For the exercise of any of your rights, you can contact our Data Protection Officer at privacy@clearscore.com.

Changes we make to our privacy notice

We reserve the right to update this People Privacy Notice at any time and any substantial changes we make will be notified to you by email. Please check back frequently to see any updates or changes to this notice.

Contact us

You can address any questions, comments, complaints or requests regarding this People Privacy Notice to the Data Protection Officer at privacy@clearscore.com. You may also write to us at the following address:

Clear Score Technology Limited Attn: Data Protection Officer Vox Studios VG 203, 1-45 Durham Street, London, SE11 5JH

Your right to lodge a complaint with the ICO

If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact our Data Protection Officer. However, you can make a complaint to the Information Commissioner’s Office (ICO) at any time. For more information please access: https://ico.org.uk/.