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Swish Fibre Job Applicant Privacy Notice

This notice is effective from 22 December 2020


This Job Applicant Privacy Notice applies to Swish Fibre Limited and, as the context requires, each of its subsidiary companies (hereinafter referred to below as “Swish”, “we”, “us” and “our”). Our contact details can be found at the end of this privacy notice.


Swish has appointed Carol Smith as the person with responsibility for data protection compliance regarding HR-related personal data. She can be contacted at Questions about this policy, or requests for further information, should be directed to her. 

As part of any recruitment process, Swish collects and processes personal data relating to job applicants. Swish is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Swish collect?

Swish collects a range of information about you. This may include:

  • your name, address and contact details, including email address and telephone number

  • details of your qualifications, skills, experience and employment history

  • information about your current level of remuneration, including benefit entitlements

  • whether or not you have a disability for which Swish needs to make reasonable adjustments during the recruitment process; and

  • information about your entitlement to work in the UK.

Swish may collect this information in a variety of ways. For example, data might be contained in application forms or CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Swish may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Swish will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.


Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does Swish process personal data?


Swish needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, Swish needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

Swish has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Swish to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Swish may also need to process data from job applicants to respond to and defend against legal claims.

Swish may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. Swish processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, Swish may be obliged to seek information about criminal convictions and offences. Where Swish seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

Who has access to data?


Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and Recruitment Team, Office Manager, interviewers involved in the recruitment process, leaders and managers in the business and IT staff if access to the data is necessary for the performance of their role.

Swish will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Swish will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and, where appropriate for the role. the Disclosure and Barring Service to obtain necessary criminal records checks.

Swish will not transfer your data outside the European Economic Area.

How does Swish protect data?

Swish takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.  Further information can be provided on request.

For how long does Swish keep data?


We will retain your personal data for only as long as is necessary for the recruitment process. If your application for employment is unsuccessful, Swish will hold your data on file for six months after the end of the relevant recruitment process your data is deleted or destroyed. 

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in anemployee privacy notice when you first join Swish.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request


  • require Swish to change incorrect or incomplete data


  • require Swish to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and


  • withdraw your consent at any time where we are using your personal data with your consent, and

  • object to the processing of your data where Swish is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, contact Chris Cope,

If you believe that Swish has not complied with your data protection rights, you can complain to the Information Commissioner.


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Swish during the recruitment process. However, if you do not provide the information, Swish may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.


Making a complaint


The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.


If you wish to contact us or raise a complaint on how we have handled your information, you can contact us, and we will investigate the matter, via e-mail at or write to us at Data Protection, Swish Fibre Ltd, 13 Salisbury Place, London, W1H 1FJ.

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