Applicant Privacy Notice

Segritude Ltd (“Segritude”, “the studio”, “we”, “us” or “our”) is committed to protecting the privacy of everyone who applies to work or collaborate with us. This notice explains what personal data we collect about you when you apply for a role, position or contributor engagement with the studio, how and why we use it, who we share it with, how long we keep it, and the rights you have over it.

1. About this notice

For the purposes of data protection law, we are the “controller” of the personal data we collect about applicants. This means we are responsible for deciding how and why your personal data is processed. Our details are set out below.

• Legal name: Segritude Ltd.
• Registered in: England and Wales, company number 14881516.
• Registered office: 17 Crown Apartments, Christchurch Court, Banbury, Oxfordshire, OX16 5EN, United Kingdom.
• Contact for recruitment and privacy queries: careers@segritude.com.

We handle your personal data in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other data protection law that applies to us.

This notice applies to candidates and applicants. If you go on to join the studio, we will give you a separate privacy notice covering how we handle personal data during your engagement with us.

2. The personal data we collect about you

Personal data means any information that relates to an identifiable person. During recruitment we may collect and use the following categories of personal data about you.

• Identity and contact details: your name, email address, telephone number, postal address, country or location, and any usernames you use to communicate with us, such as your Discord username.
• Application information: the details in your application, your CV or résumé, your cover letter or message, your portfolio, showreel, and links to your work, such as a personal website, GitHub, ArtStation, or similar professional profiles.
• Background and experience: your employment history, education, skills, qualifications and certificates, together with your availability and the role or roles you are interested in.
• Recruitment and assessment information: records of our correspondence with you, information you share during interviews (which we usually hold over a voice call on Discord), the outcome of any exercises, tasks or tests, interviewer notes, feedback and assessments, and references where we take them.
• Identity, eligibility and verification information: where we decide to engage you, we may need to verify your identity, your eligibility to work or to provide services to us, and any qualifications or certificates you rely on. This may include a document that confirms your identity.
• Communications: the content of emails, messages and other correspondence between you and the studio that relate to your application.
• Technical and usage data: if you contact us or apply through our website, we may collect limited technical information such as your internet protocol (IP) address and basic information about your device and how you use the site.

We aim to collect only the personal data we need for recruitment. Please do not send us more information than we ask for. In particular, please avoid including special category data (described in section 5) in your application unless we specifically request it.

3. How we collect your personal data

We collect personal data about you in the following ways.

• Directly from you: when you contact us, submit an application, complete a form, take part in an interview, or otherwise communicate with us about a role.
• From third parties: from referees you have named, from a recruiter or introducer where you have applied through one, and from publicly available professional sources such as portfolio platforms or professional networking profiles, where they are relevant to the role.
• Automatically: through our website, where limited technical data may be collected when you visit the site or contact us. Please see our Privacy Policy for more detail on this.

4. Why we use your personal data, and our lawful bases

We only use your personal data when the law allows us to. In most cases we rely on one or more of the following lawful bases: to take steps at your request before deciding whether to enter into a contract or engagement with you; our legitimate interests in running a fair, efficient and effective recruitment process, provided your interests and rights do not override those interests; compliance with a legal obligation to which we are subject; and your consent, where we specifically ask for it.

The table below sets out the main purposes for which we use your personal data and the lawful basis we rely on for each.

Purpose	Lawful basis
Assessing your application, skills and suitability for a role	Taking steps at your request before entering a contract; our legitimate interests
Communicating with you about your application and arranging interviews	Taking steps at your request before entering a contract; our legitimate interests
Carrying out interviews, exercises and assessments	Taking steps at your request before entering a contract; our legitimate interests
Taking up references, and verifying your identity, eligibility and qualifications where we decide to engage you	Taking steps at your request before entering a contract; compliance with a legal obligation; our legitimate interests
Keeping records of the recruitment process, and establishing, exercising or defending legal claims	Our legitimate interests; compliance with a legal obligation
Keeping your details on file to consider you for future roles	Your consent
Handling requests for adjustments to our recruitment process, and any equal opportunities information you choose to give us	Your explicit consent, or another condition permitted for special category data (see section 5)

Where we rely on our legitimate interests, we consider and balance any potential impact on you and your rights before we proceed. You can ask us for more information about this balancing exercise using the contact details in section 14.

5. Special category and criminal offence data

Some personal data is treated as more sensitive and is given extra protection by law. This “special category data” includes information about your health, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, and similar matters.

We do not routinely ask applicants for special category data. We may come to hold it only where:

• you choose to share it with us, for example when you ask us to make an adjustment to our recruitment process to support a disability or health condition; or
• we invite you, on a voluntary basis, to provide equal opportunities information, which we keep separate from your application and use only in aggregated or anonymised form wherever possible.

Where we process special category data, we do so on the basis of your explicit consent, or another condition permitted under the UK GDPR and the Data Protection Act 2018, such as reasons of substantial public interest connected with equality of opportunity or treatment. Where we rely on your consent, you can withdraw it at any time.

We do not routinely carry out criminal records checks as part of recruitment. If a particular role ever requires one, we will tell you before we do so and explain the basis on which we process that information.

6. Automated decision-making

We do not make decisions about your application based solely on automated processing, that is, without any human involvement, where those decisions produce legal effects concerning you or similarly significantly affect you. A person from our team is always involved in our recruitment decisions.

7. Who we share your personal data with

We treat your personal data with care and only share it where there is a proper reason to do so. We may share it with the following recipients.

• People within the studio: members of our team who are involved in the recruitment process, such as the relevant hiring lead, interviewers, and the director, on a need-to-know basis.
• Service providers who process data on our behalf: the providers of the tools and infrastructure we use to run recruitment. These may include communication and interview tools (for example, Discord), email, document and storage services (for example, Google), our internal candidate and onboarding systems, and our hosting, information technology and security providers. These providers act on our instructions and are required to keep your personal data secure and to use it only for the purposes we specify.
• Our professional advisers: such as our legal and accountancy advisers, where their involvement is necessary.
• Authorities and other third parties: where we are required to share information by law, or where it is necessary to establish, exercise or defend legal rights.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

8. Transfers outside the United Kingdom

Some of the service providers we use are based outside the United Kingdom, including in the United States. This means your personal data may be transferred to, stored in, or accessed from a country outside the UK.

Whenever we transfer personal data outside the UK, we make sure a similar degree of protection applies by relying on an appropriate safeguard, such as:

• a decision by the UK government that the country in question provides an adequate level of protection for personal data; or
• standard data protection clauses approved for use in the UK, such as the International Data Transfer Agreement, or the UK Addendum to the European Commission’s standard contractual clauses; or
• another safeguard permitted under UK data protection law.

You can ask us for more information about the safeguards we use for a particular transfer by contacting us using the details in section 14.

9. How long we keep your personal data

We keep your personal data only for as long as we need it for the purposes set out in this notice.

• If your application is not successful, we will normally keep your recruitment data for up to 12 months after we tell you our decision, so that we can deal with any queries or complaints and consider you for other suitable roles that arise in that period. After that, we will securely delete or anonymise it.
• If you ask us, or agree, to keep your details on file for future opportunities, we will keep them for up to 12 months from the date of your consent, unless you ask us to remove them sooner. We may ask nearer the time whether you would like us to keep them for longer.
• If your application is successful, the personal data collected during recruitment will become part of your engagement records, which we will keep in line with the separate privacy notice we give you when you join.

We may keep certain information for longer where we need to in order to comply with a legal obligation, or to establish, exercise or defend legal claims.

10. How we keep your personal data secure

We take the security of your personal data seriously and use appropriate technical and organisational measures to protect it against loss, misuse, and unauthorised access. These measures include restricting access to your personal data to those who need it for the recruitment process, controlling access to our systems by role, using secure and access-controlled infrastructure, and placing confidentiality obligations on the people who work with us. We review our measures as the studio grows and as our tools change.

11. Your rights

Under data protection law, you have a number of rights in relation to your personal data. These include the right to:

• be informed about how we collect and use your personal data, which is the purpose of this notice;
• request access to the personal data we hold about you, and to receive a copy of it;
• request correction of personal data that is inaccurate or incomplete;
• request erasure of your personal data, where there is no good reason for us to continue processing it;
• request restriction of our processing of your personal data in certain circumstances;
• object to our processing of your personal data where we rely on our legitimate interests;
• request the transfer of your personal data to you or another organisation in a structured, commonly used and machine-readable format, where we process it by automated means on the basis of your consent or a contract; and
• withdraw your consent at any time, where we rely on your consent to process your personal data. Withdrawing your consent will not affect the lawfulness of any processing we carried out before you withdrew it.

You will not usually have to pay a fee to exercise your rights. We will respond to your request within one month. We may extend this period for particularly complex requests and, if we do, we will let you know. We may need to ask you for information to confirm your identity before we act on a request.

To exercise any of your rights, please contact us using the details in section 14.

12. Your right to complain

We hope that we can resolve any question or concern you have about the way we handle your personal data, so please do contact us first using the details in section 14. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection.

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.

13. Changes to this notice

We may update this notice from time to time, for example to reflect changes in the way we work or in the law. When we make a significant change, we will update the date shown on this page and, where appropriate, we will tell candidates who are currently in our recruitment process.

14. How to contact us

If you have any questions about this notice, or you would like to exercise any of your rights, please contact us.

• By email: careers@segritude.com
• By post: Data Protection, Segritude Ltd, 17 Crown Apartments, Christchurch Court, Banbury, Oxfordshire, OX16 5EN, United Kingdom.