Candidate Data Retention Policy

Policy Title: Candidate Data Retention Policy
Issue date (mm/yy): August 2026
Author(s): People and Culture
Approved by: Gavin Pooley
Review date: August 2027
Related Policies & Procedures: Privacy Policy
Version: 1

Policy
We are committed to protecting the privacy and security of personal information provided by candidates throughout our recruitment process. This policy outlines how candidate data is collected, stored, retained, and securely disposed of in accordance with applicable data protection legislation.

Scope
This policy applies to all personal data collected from job applicants or other sources, whether submitted through our website, recruitment agencies, job boards, email applications, or any other recruitment channel.

Information We Collect
As part of the recruitment process, we may collect:

• Contact information (name, address, telephone number, email address)
• CVs and employment history
• Qualifications and certifications
• Interview notes and assessment results
• References and background check information (where applicable)
• Right to work documentation
• Information relating to reasonable adjustments required during the recruitment process
• Any other information voluntarily provided by the candidate

How We Use the Information
We will typically collect and use the information for the following purposes:

• To assess your skills, qualifications, and suitability for a role
• To communicate with you about the recruitment process
• To carry out background and reference checks
• To take steps to enter into a contract with you
• For compliance with a legal obligation
• For the purposes of our legitimate interests or those of a relevant third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms
• For the purposes of a recognised legitimate interest (e.g. to share it with an organisation that needs the data for a public task, to detect, investigate or prevent crime, or to protect a vulnerable individual)
• Because it is necessary for carrying out obligations or exercising rights in employment law
• To establish, exercise and/or defend any legal claims that may be brought by or against us in connection with your recruitment.

How We May Share the Information
We may share some of the above categories of information with other parties, such as HR consultants and professional advisers. The recipient will only be allowed to process the data for specified purposes and in accordance with our instructions. We may also be required to share some personal data as required to comply with the law.

Data Retention Periods

Successful Candidates
Where a candidate is successfully appointed, relevant recruitment records will be transferred to the individual’s employee file and retained in accordance with the Employee Data Retention Policy.
Unsuccessful Candidates

Unless otherwise agreed by a candidate as specified below, personal data relating to unsuccessful candidates will be retained for 6 months following the conclusion of the recruitment process. This enables us to:

• Respond to feedback requests
• Defend potential legal claims
• Consider candidates for future suitable opportunities (where consent has been provided)

At the end of the retention period, candidate records will be securely deleted or anonymised.

Talent Pool Candidates
Where candidates have given consent to be considered for future opportunities, their details may be retained in our talent pool for up to 24 months. Consent can be withdrawn at any time by contacting us.

Special Category Data
Any information relating to health conditions, disabilities, or reasonable adjustment requirements will be used solely for the purpose of facilitating an accessible recruitment process and will be retained only for as long as necessary to fulfil that purpose.

Candidate Rights
Candidates have the right to:

• Request access to their personal data
• Request correction of inaccurate information
• Request deletion of their personal data where applicable
• Object to or restrict processing
• Withdraw consent where processing is based on consent

Requests can be made by contacting our IT or People & Culture team.

Data Security
We implement appropriate technical and organisational measures to protect candidate data from unauthorised access, loss, alteration, or disclosure. Access to recruitment information is restricted to employees and third parties who require it for legitimate recruitment purposes.

Disposal of Data
Once the applicable retention period has expired, candidate information will be securely deleted from our systems or irreversibly anonymised.

How To Complain
If you wish to make a complaint about the way we handle, or have handled, your information you can email people@liquidline.co.uk.
We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint, which will usually involve:

• Reviewing your complaint;
• Locating and reviewing the records we hold about you;
• Establishing the relevant facts; and
• Taking any other steps necessary such as liaising with individuals who you may have dealt with.

We may also need to ask you for further information, in which case we will ask you to provide it within a specific period of time.
We will update you on the progress of your complaint at appropriate times and we will inform you of the outcome of the complaint without undue delay. We will explain clearly what we’ve done to resolve your complaint and, where appropriate, any action we have taken as a result.

If you are unhappy with the outcome of your complaint, you can complain to the Information Commissioner’s Office (ICO). The ICO is responsible for data protection issues in the UK and its contact details are:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113

Policy Review
This policy will be reviewed periodically to ensure ongoing compliance with data protection legislation and best practice.