RECRUITMENT PRIVACY POLICY
Last Updated: February 2026
Kinetic Software ("we", "us", or "our") is committed to protecting your privacy. This Recruitment Privacy Policy explains how we collect, use, store, and share your personal data when you interact with our recruitment process.
This policy applies if you:
- Visit our Career Site.
- Create a candidate profile with us.
- Apply for a position with us.
- Are contacted by us about potential opportunities.
- Are listed as a reference by a candidate.
1. Who We Are (Data Controller)
Kinetic Software is the data controller for the personal data described in this policy. This means we determine how and why your data is processed.
Our contact details:
- Company Name: Kinetic Solutions Ltd
- Registered Address: 249 Silbury Boulevard Milton Keynes, MK9 1NA
- Email: Hayley.Doody@kineticsoftware.com
- Data Protection Officer (if applicable): Please contact Hayley Doody
2. What Personal Data We Collect
The personal data we collect depends on how you interact with us. "Personal data" means any information that relates to an identified or identifiable individual.
2.1 All Visitors to Our Career Site
- Device Information: IP address, browser type and version, device type, operating system, screen resolution.
- Usage Information: Pages visited, time spent on site, referring URLs, clickstream data.
- Contact Details: Name, email address, phone number, mailing address, LinkedIn profile.
- Application Materials: CV/resume, cover letter, work samples, portfolio, certifications, qualifications.
- Professional Information: Work history, education, skills, professional memberships, publications.
- Recruitment Process Data: Interview notes, assessment results, scoring, recruiter evaluations, salary expectations.
- Communications: Emails, messages, phone call notes, interview recordings (with consent).
- References: Reference contact details and feedback from references.
- Right to Work: Visa status, work authorisation documents (where legally required).
- Diversity Information: Ethnicity, gender, disability status for equal opportunities monitoring.
- Contact Details: Name, job title, organisation, email address, phone number.
- Reference Feedback: Information you provide about the candidate.
2.2 Job Applicants and Candidates
- Contact Details: Name, email address, phone number, mailing address, LinkedIn profile.
- Application Materials: CV/resume, cover letter, work samples, portfolio, certifications, qualifications.
- Professional Information: Work history, education, skills, professional memberships, publications.
- Recruitment Process Data: Interview notes, assessment results, scoring, recruiter evaluations, salary expectations.
- Communications: Emails, messages, phone call notes, interview recordings (with consent).
- References: Reference contact details and feedback from references.
- Right to Work: Visa status, work authorisation documents (where legally required).
- Diversity Information: Ethnicity, gender, disability status for equal opportunities monitoring.
2.3 References
- Contact Details: Name, job title, organisation, email address, phone number.
- Reference Feedback: Information you provide about the candidate.
3. How We Collect Your Personal Data
3.1 Directly From You
Most information comes directly from you when you:
- Complete application forms on our Career Site.
- Upload your CV/resume and other documents.
- Create a candidate profile.
- Communicate with us via email, phone, or video calls.
- Participate in interviews and assessments.
3.2 From Third-Party Platforms
We may receive your application or profile from:
- Job boards (e.g., LinkedIn, Indeed)
- Recruitment agencies: Various recruitment partners.
- Employee referral programs.
3.3 From Public Sources
In some cases, we may proactively source candidates by collecting publicly available information from:
- Professional networking sites (e.g., LinkedIn).
- Professional organisation websites.
- Company websites and professional portfolios.
Important Note About Proactive Sourcing:
If we identify you as a potential candidate through public sources, we will contact you to inform you that we have your information and to seek your consent to continue processing your data for recruitment purposes. You can decline at any time.
3.4 From Your References
If you provide references, we will collect information about you from the individuals you list. Important: By providing reference contact details, you confirm that you have informed your references and obtained their consent for us to contact them.
3.5 From Our Recruitment Systems
We create data about you during the recruitment process, including interview notes, assessment scores, and internal evaluations.
4. How and Why We Use Your Personal Data
We process your personal data for the following purposes, with the corresponding legal bases under GDPR:
Purpose
Legal Basis
Who This Affects
Processing and evaluating your application for specific vacancies
Legitimate Interest - recruiting qualified candidates
Job applicants
Retaining your data to consider you for future opportunities
Consent - you can withdraw anytime
Unsuccessful applicants who opt in
Proactively sourcing candidates from public sources
Legitimate Interest initially; Consent sought upon contact
Sourced candidates
Recording interviews (video/audio)
Consent - explicitly requested before recording
Candidates who consent to recording
Communicating with you about your application and recruitment process
Legitimate Interest - managing recruitment
All candidates
Conducting reference checks
Legitimate Interest - verifying candidate suitability
Candidates and their references
Maintaining and securing our Career Site
Legitimate Interest - site security and functionality
All website visitors
Analysing site performance and improving user experience
Legitimate Interest - optimising recruitment process
All website visitors
Complying with legal obligations (e.g., equal opportunities monitoring, employment law)
Legal Obligation
All candidates
Establishing, exercising, or defending legal claims
Legitimate Interest - protecting legal rights
Affected individuals as relevant
Note on Automated Decision-Making:
We do not use automated decision-making or profiling that would have legal or similarly significant effects on you. All recruitment decisions involve human review and judgment.
5. Who We Share Your Personal Data With
We may share your personal data with the following categories of recipients:
5.1 Internal Recipients
- Hiring Managers: For reviewing applications and conducting interviews.
- P&C Team: For managing the recruitment process.
- Relevant Team Members: Who participate in interviews or assessments.
5.2 Third-Party Service Providers
We use trusted service providers who process data on our behalf:
- Applicant Tracking System: Team Tailor
- Video Interview Platform: Microsoft Teams
- Assessment Tools: Testdome and Thomas International
- Cloud Storage Providers: AWS and Azure
- Email and Communication Platforms: Microsoft 365
- Recruitment Agencies: Various recruitment partners.
These service providers are contractually obligated to process your data only as instructed by us and to implement appropriate security measures.
5.3 Group Companies
We may share your data with our parent company, subsidiaries, and affiliated companies within the Volaris / Constellation group for: recruitment administration, considering you for positions across the group, shared IT services. Group companies are located worldwide.
5.4 Legal and Regulatory Authorities
We may disclose your personal data to regulatory bodies, law enforcement, or other authorities when:
- Required by law or legal process.
- Necessary to establish, exercise, or defend legal claims.
- Required to protect vital interests or public safety.
5.5 Business Transfers
In the event of a merger, acquisition, sale of assets, or corporate restructuring, your personal data may be transferred to the acquiring organisation. We will notify you of any such transfer and ensure the new controller respects your privacy rights.
6. International Data Transfers
Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including:
When we transfer data internationally, we ensure appropriate safeguards are in place:
- Adequacy Decisions: We transfer data to countries recognised by the EU Commission as providing adequate protection (e.g., UK, countries certified under the EU-US Data Privacy Framework).
- Standard Contractual Clauses: We use EU Commission-approved Standard Contractual Clauses with service providers in non-adequate countries.
- Additional Safeguards: We implement technical and organisational measures such as encryption, access controls, and data minimisation.
You can request more information about international transfers and obtain copies of safeguards by contacting us at Kinetic.
7. How Long We Keep Your Personal Data
We retain your personal data only for as long as necessary for the purposes described in this policy. Retention periods vary based on your relationship with us:
7.1 Unsuccessful Applicants
- With Your Consent: If you consent to us keeping your data for future opportunities, we will retain your information for 24 months from your last interaction with us.
- Without Consent: If you do not consent or once the retention period expires, we will delete your data within 60 days.
- Withdrawing Consent: You can withdraw your consent and request deletion at any time by contacting us.
7.2 Successful Applicants (Hired)
If you are hired, your recruitment data becomes part of your employee record and is retained according to our Employee Privacy Policy. You will receive this policy upon hire.
7.3 Candidate Profile Accounts
If you create a candidate profile account on our Career Site, we will retain your data until you delete your account or for 24 months of inactivity, whichever comes first.
7.4 References
Reference information is retained for the same period as the candidate's data.
7.5 Website Visitors
Website usage data and cookies are retained according to our Cookie Policy.
7.6 Legal Requirements
We may retain personal data beyond the standard periods if required by law (e.g., tax records, discrimination claims) or to establish, exercise, or defend legal claims.
8. How We Protect Your Personal Data
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse:
- Encryption: Data in transit and at rest is encrypted.
- Access Controls: Only authorised personnel have access to your data on a need-to-know basis.
- Security Training: Staff are trained on data protection and security.
- Regular Audits: We conduct regular security assessments.
- Vendor Management: Third-party processors are vetted and contractually bound to maintain security.
While we take reasonable precautions, no security system is impenetrable. If we become aware of a data breach that affects your rights, we will notify you and relevant authorities as required by law.
9. Your Privacy Rights
Under data protection law (including GDPR), you have the following rights regarding your personal data:
9.1 Right of Access
You can request a copy of the personal data we hold about you. We will provide this free of charge in electronic format within one month of your request.
9.2 Right to Rectification
You can request that we correct inaccurate or incomplete personal data. You can also update your information directly through your candidate profile account.
9.3 Right to Erasure (Right to be Forgotten)
You can request deletion of your personal data in certain circumstances:
- The data is no longer necessary for the purpose it was collected.
- You withdraw consent (where consent was the legal basis).
- You object to processing and there are no overriding legitimate grounds.
- The data was unlawfully processed.
Note: This right is not absolute. We may need to retain certain data for legal compliance or to establish, exercise, or defend legal claims.
9.4 Right to Restrict Processing
You can request that we limit how we use your data if:
- You contest the accuracy of the data (until we verify accuracy).
- Processing is unlawful but you don't want data deleted.
- We no longer need the data but you need it for legal claims.
- You object to processing (pending verification of legitimate grounds).
9.5 Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you can request a copy of your data in a structured, machine-readable format (e.g., CSV, JSON) and have it transmitted to another organisation where technically feasible.
9.6 Right to Object
You can object to processing of your personal data where we rely on legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests.
For sourced candidates: If we contact you about opportunities you didn't apply for, you have an absolute right to object to further processing. Simply notify us and we will delete your data.
9.7 Right to Withdraw Consent
Where processing is based on consent (e.g., keeping your data for future opportunities, recording interviews), you can withdraw consent at any time. This won't affect processing that occurred before withdrawal.
9.8 Right to Lodge a Complaint
If you're unhappy with how we process your data, you have the right to complain to a supervisory authority:
9.9 How to Exercise Your Rights
To exercise any of these rights, you can:
- Email us: Hayley.doody@kineticsoftware.com
- Log into your candidate account: Manage preferences and data directly.
- Write to us: 240 Silbury Boulevard, Milton Keynes MK9 1NA
We will respond to requests within one month (extendable by two months for complex requests). We may need to verify your identity before processing requests.
10. Cookies and Tracking Technologies
Our Career Site uses cookies and similar technologies to:
- Enable essential site functionality.
- Analyse site performance and user behaviour
- Remember your preferences.
- Deliver targeted recruitment advertising.
For detailed information about the cookies, we use, purposes, retention periods, and how to manage your preferences, please see our Cookie Policy.
11. Children's Privacy
Our recruitment services are not directed at individuals under 18 We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will:
- Update the "Last Updated" date at the top of this policy.
- Notify active candidates by email.
- Post a notice on our Career Site.
We encourage you to review this policy periodically. Continued use of our recruitment services after changes indicates acceptance of the updated policy.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
- Privacy Contact: Hayley.doody@kineticsoftware.com
- Data Protection Officer: As above.
- Mailing Address: 249 Silbury Boulevard, Milton Keynes, MK9 1NA
