Privacy Policy

1. Who we are

ClearCandidate Ltd is the data controller for personal data processed through this Platform. We are registered in England and Wales.

Contact: privacy@clearcandidate.co.uk

We are registered with the Information Commissioner's Office (ICO) as a data controller.

2. What data we collect

All users (Candidates and Employers)

• Name, email address, and phone number (provided at registration)
• Password (stored as a one-way hash — we cannot read it)
• IP address and browser information (collected automatically)
• Account activity logs

Candidates

• Public profile data: primary sector, role title, years of experience, skills, qualifications, broad region, work schedule preference, hiring track preferences, driving licence categories and penalty points, professional licence/registration codes, DBS certificate level and workforce type, DBS certificate issue date, DBS Update Service status, availability status
• Private location data: home postcode and geocoded coordinates (used only for commute-distance filtering — never shown to employers)
• Right to work: document type, share code (for EUSS/eVisa holders), RTW expiry date
• Sensitive identity data: National Insurance number, right to work declaration
• CV: uploaded document stored encrypted in cloud storage (AWS S3)
• Work history: role titles, sectors, and dates (no company names)
• Genuine interest data: desired industries and role types, personal statement

Employers

• Company name, sector, and contact details
• Subscription and billing information (payment card details are held by Stripe, not by us)
• Job opening details and hiring request history
• Candidate shortlists

Usage and technical data

• Pages visited, search filters used, and actions taken on the Platform
• Device type and operating system
• Authentication tokens (stored server-side; JWT issued to your device)

3. How we use your data

Candidates

• To create and display your anonymous public Profile to Employers
• To calculate commute-distance filtering when Employers search by job postcode (your postcode is processed server-side and never revealed)
• To verify your right to work status (via our internal admin process)
• To provide your identity and contact details to an Employer only after Clearance
• To record your work history following completed placements
• To enable Employers to submit ratings of your work (with your NI number used solely for payroll identification purposes post-clearance)
• To send you notifications about Hiring Requests, Agreement updates, and platform changes

Employers

• To manage your subscription and process payments via Stripe
• To enable you to browse anonymous Candidate Profiles and send Hiring Requests
• To provide Cleared Candidate data after a valid Agreement
• To manage your shortlist, pipeline, and placement history

All users

• To maintain platform security and prevent fraud
• To comply with our legal obligations
• To send transactional emails (account setup, Agreement notifications, password reset)
• To improve the Platform based on aggregated, anonymised usage data

4. Lawful basis for processing

We rely on the following lawful bases under UK GDPR:

• Contract: Processing necessary to provide the service you have signed up for (running your Profile, processing Hiring Requests, managing subscriptions).
• Legal obligation: Retaining records of right to work declarations and Agreements as required by UK employment and immigration law.
• Legitimate interests: Platform security, fraud prevention, improving our service, and providing commute-distance filtering. We have assessed that these interests are not overridden by your rights.
• Consent: Where we send you optional marketing communications. You can withdraw consent at any time.

5. Special category and sensitive data

The following data we process is either special category data under UK GDPR or particularly sensitive:

Right to work documents

Processing is necessary for compliance with our legal obligation to support lawful employment and the Employer's obligation under the Immigration, Asylum and Nationality Act 2006. This data is only shared with the relevant Employer after Clearance.

National Insurance number

Processed on the basis of contract (it forms part of the post-clearance employment information provided to the Employer). We do not use NI numbers for any other purpose.

DBS certificate information

Candidates self-declare their DBS status. We do not receive, verify, or store actual DBS certificate numbers. The level, workforce type, issue date, and Update Service status declared by the Candidate are processed on the basis of legitimate interests (enabling Employers in regulated sectors to identify appropriately checked candidates). Employers remain responsible for obtaining their own DBS check or running an Update Service check prior to employment.

Criminal record data

Basic DBS results (unspent convictions) may be inferred from a Candidate's DBS level declaration. We do not ask Candidates to disclose conviction details. Any such data is processed solely to the extent necessary for employment facilitation.

6. Who we share your data with

We do not sell personal data. We share data only in the following circumstances:

• Employers (post-Clearance): A Candidate's full profile is shared with the specific Employer with whom Clearance has occurred, and no other.
• Stripe: Payment processing for Employer subscriptions. Stripe is our data processor under a data processing agreement.
• Heroku (Salesforce): Our application hosting provider. Servers are located in the EU. Data processing agreement in place.
• Amazon Web Services (S3): Encrypted cloud storage for CV files. Data processing agreement in place.
• postcodes.io: An open API used to geocode UK postcodes for distance filtering. Only the postcode is sent; no personal details accompany it.
• Legal authorities: If required by law or court order.

7. How long we keep your data

• Active accounts: Data is retained for as long as your account is active.
• Deleted Candidate accounts: Public profile data is deleted immediately. Private data (NI number, RTW documents, CV) is deleted within 30 days. Work history created from completed placements is anonymised and retained for platform statistics.
• Agreements and Clearance records: Retained for 6 years from the date of the placement to comply with employment record-keeping obligations.
• Payment records: Retained for 7 years to comply with HMRC requirements.
• Right to work records: Retained for the duration of employment plus 2 years, as required by the Home Office right to work guidance.
• Inactive accounts: We will contact you after 24 months of inactivity and delete your account if we do not receive a response within 30 days.

8. International transfers

Our primary infrastructure is hosted in the EU (Heroku EU region). CV files are stored in AWS S3 in the EU (eu-west-1 / Ireland). We do not routinely transfer personal data outside the UK or EEA. In the event any transfer is necessary, we will ensure it is protected by appropriate safeguards (UK adequacy decisions, standard contractual clauses, or binding corporate rules).

9. Your rights

Under UK GDPR you have the following rights. To exercise any of them, contact us at privacy@clearcandidate.co.uk. We will respond within one calendar month.

• Access: Request a copy of the personal data we hold about you.
• Rectification: Ask us to correct inaccurate or incomplete data. You can also update most data directly in your account settings.
• Erasure: Ask us to delete your data (the "right to be forgotten"), subject to our legal retention obligations.
• Restriction: Ask us to restrict processing of your data in certain circumstances.
• Portability: Receive your data in a structured, machine-readable format.
• Object: Object to processing based on legitimate interests. We will stop unless we have compelling legitimate grounds.
• Withdraw consent: Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.
• Automated decisions: We do not make solely automated decisions with legal or significant effects about you.

10. Security

We implement technical and organisational measures to protect your data, including:

• All data in transit is encrypted using TLS 1.2 or higher.
• Passwords are hashed using bcrypt and never stored in readable form.
• Authentication tokens (JWTs) are short-lived and rotated on refresh.
• On mobile devices, tokens are stored in hardware-backed secure storage (iOS Keychain / Android Keystore).
• CV files are stored encrypted at rest in AWS S3 and served via time-limited pre-signed URLs.
• Access to production data is restricted to authorised personnel only.

No system is completely secure. In the event of a data breach that is likely to result in a risk to your rights, we will notify the ICO within 72 hours and inform affected individuals without undue delay.

11. Children

The Platform is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at privacy@clearcandidate.co.uk and we will delete it promptly.

12. Changes to this policy

We may update this policy from time to time. We will notify you of material changes by email at least 14 days before they take effect. The date at the top of this page shows when it was last updated.

13. Contact & complaints

For any privacy-related query or to exercise your rights:

Email: privacy@clearcandidate.co.uk
Post: Data Protection, ClearCandidate Ltd, [Registered Address]

If you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Helpline: 0303 123 1113