PURPOSE
This privacy notice gives job applicants information about how their personal data will be used.
This privacy notice applies to all candidates who are located within the European Union (EU), European Economic Area (EEA), United Kingdom (UK) or United States (US).
This document reflects the requirements of UK, EU and US privacy laws, hereinafter referred to as the Data Protection Legislation.
Data Protection Legislation means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Data (Use and Access) Act 2025, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time. California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) is applicable to US candidates.
PRIVACY NOTICE
As part of any recruitment process, Croud Inc. Ltd. and Croud Incorporated (together referred to as the “We”, “Us”, “Our”, “Organization”, “Croud”) collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. We determine the purposes and means of processing and, therefore, act as the Data Controller of your personal data under applicable data protection laws. If you have any questions regarding this Notice you can contact us at dpo@croud.com.
What information does the organisation collect?
The organisation collects a range of information about you. This includes:
your name, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history;
information from interviews and phone-screenings you may have;
information about your current level of remuneration, including benefit entitlements;
whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
information about your entitlement to work in the UK; and
equal opportunities monitoring information, including information about your ethnic origin and health.
The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your identity documents, or collected through interviews or other forms of assessment, including online tests.
The organisation may also collect personal data about you from third parties, such as references supplied by former employers, information from recruitment organisations, information from employment background check providers and information from criminal records checks. The organisation will seek information from third parties both as part of its wider selection process to ensure that its process is managed as efficiently as possible and then after 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). Please note that we do not use identifiable personal data to train general AI models.
Personal Data we receive or generate during recruitment
We will use third party recruitment tools, including AI assisted technologies, to help review applications. These tools will generate summaries, assessments, rankings, or scores based on information provided during the recruitment process. All recruitment decisions are made by recruiters and hiring managers, who review and consider these outputs alongside their own assessment.
Why does the organisation process personal data?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation 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. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
The organisation 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 the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the organisation processes other special categories of data, such as information about ethnic origin or health, this is for equal opportunities monitoring purposes.
If your application is unsuccessful, we will retain your personal data for 6 months after the recruitment process has concluded in accordance with our data retention policy. This allows us to manage the recruitment process, respond to queries, and meet any legal or regulatory obligations.
With your consent, we would also like to retain your personal data for a further 12 months so that we can contact you about future employment opportunities that may be suitable for your skills and experience. If you do not provide consent, your data will be deleted or securely destroyed at the end of the standard retention period.
You can withdraw your consent at any time by contacting dpo@croud.com. Once the retention period ends, or if you withdraw your consent, your personal data will be deleted or securely destroyed in line with our retention policy.
Who has access to personal data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles in the recruitment process.
We may also share personal data with external third parties we use to help support us in the application process i.e. website hosts, IT and systems administrators, recruitment tools. We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. Third parties may benefit from AI. We have contracts in place and conduct the necessary data protection impact assessments. In addition, we have both policies and technical controls implemented to minimise any impact on individuals.
We may also occasionally share personal data with:
our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; or
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
The organisation will not share your data with your former employer, unless your application for employment is successful and you accept an offer of employment. The organisation will then share your data with former employers to obtain references for you.
We may also share your data with our group companies, for business performance and other types of monitoring and management purposes and, if you are applying for a senior management position with us, we may share your data with our investors.
The organisation will not transfer your data outside the European Economic Area.
Automated decision-making
We do use technology systems, including those which use artificial intelligence as part of our recruitment, however recruitment processes are never based solely on automated decision-making. Technology is designed as a decision-support tool only, and at all times, final decisions remain with Croud. Appropriate human oversight is maintained throughout the recruitment process.
How does the organisation protect data?
The organisation 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.
Recruiting managers and interviewers will have access to the personal information required to carry out their role in the recruitment process. This may include access to the application details, CVs and other information provided during the recruitment process via our Applicant Tracking System and other approved business systems. Access is managed by the HR function on a role-based, need-to-know basis and is regularly reviewed by ensure appropriate access controls are maintained.
For how long does the organisation keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for one year after the end of the relevant recruitment process unless you request us to delete your data either through our Applicant Tracking System or directly. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further one year for consideration for future employment opportunities and / or historical purposes. At the end of that period or once you withdraw your consent, 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 a new privacy notice.
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 the organisation to change incorrect or incomplete data;
require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing, although in some cases we may demonstrate that that we have compelling legitimate grounds to continue to process your information;
ask the organisation to suspend processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data;
request the transfer of your personal data to a third party in a structured, commonly used, machine-readable format; and
withdraw consent where we are relying on consent to process your personal data.
If you would like to exercise any of these rights, please contact our DPO through dpo@croud.com, Croud Inc. Ltd., (CRN: 07542498) The Bard Building, 9th & 10th Floors, 20 Curtain Road, London, England EC2A 3NG.
If you have concerns about how we collect, use, store or otherwise handle your personal data, you have the right to make a complaint to us under the DUAA Act. You can submit a data protection complaint by emailing dpo@croud.com.
We will acknowledge receipt of your complaint within 30 days of receiving it. We will investigate your complaint, may contact you for further information if needed, and will keep you informed of progress where appropriate. We will let you know the outcome of your complaint without undue delay.
If you believe that the organisation has not complied with your data protection rights after the complaints procedure has concluded, you have a right to complain to the UK Information Commissioner’ Office (ICO) at https://ico.org.uk/make-a-complaint/ or by calling their helpline on 0303 123 1113.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
USA – Croud Incorporated: 9th Floor, 250 Hudson Street, New York, NY 10013
If you are a USA resident, we process your personal data in accordance with applicable USA state data privacy laws. These include, but are not limited to Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.
These laws comprise provisions aimed at safeguarding US consumer rights and outlining business obligations. If you have relevant rights under these laws, please refer to the Contact Us section below.
California Data Protection Legislation:
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires that we provide you with a privacy policy of our online and offline information practices and your rights under this law regarding your personal information.
We currently collect, share, disclose, and use your personal information. In the 12 months prior to the last updated date of this Privacy Notice, we have collected, shared, disclosed the personal information set out in the Your Information section above. We may collect personal information directly from California and other USA state residents, credit reporting agencies, and/or our third-party service providers. We do not collect all categories of personal information from each source.
California Resident Rights:
California residents are afforded the following rights:
to delete your personal information, unless we:
(a) can prove this to be impossible; or it involves disproportionate effort; or
(b) it is reasonably necessary for us to maintain records in order to fulfil the transaction(s) for which the personal information was collected;
to correct inaccurate personal information held about you;
to know what personal information is sold or shared and to whom (this right is fulfilled with the information provided within this Notice);
to request specific pieces of information from us;
to opt out of the sale or sharing of your personal information;
to limit use and disclosure of sensitive personal data; and,
to no retaliation following opt-out or exercise of other rights.
We Do Not Sell Your Personal Information:
You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is provided to a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA or other USA state data privacy laws.
Please note a “sale” does not include when we disclose your personal information at your direction, or when otherwise permitted under law.
We May Share Your Personal Information:
We may “share” your personal data, as defined under California and other applicable USA state laws, for personalised advertising purposes and/or for any other purposes outlined in this Privacy Notice.
Do Not Track:
Due to varying practices among browser providers and the lack of a market standard, we do not respond to Do Not Track signals at this time.
Non-Discrimination:
USA state privacy laws prohibit businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying goods or services, providing a different level or quality of service, or charging different prices.
The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.
Please contact our EU Representative at eurep@croud.com. Alternatively, they can be reached by post (The DPO Centre, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2) or +353 1 631 9460. www.dpocentre.com.
