Procure Smart

Recruitment Privacy Policy

Procure Smart Limited is committed to being transparent about how it collects and uses candidate’s personal data and to meeting its data protection obligations.  This privacy statement describes the handling of personal data obtained about internal and external job applicants, including any application via an applicant tracking system and careers page, directly by job applicants as well as by third party agencies and recruiters on behalf of candidates. Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified.

Data Controller: Procure Smart, Software Centre, 1 Tavistock Pl, Hendon, Sunderland SR1 1PB.

Data Privacy Manager: Managing Director.


Personal Data we use

1            We will collect your personal data from you directly and potentially from other sources.

1.1  Data we collect directly from you

The categories of data Procure Smart collects from you, as the applicant, include:

  • personal (e.g. name, data of birth) and contact details (e.g. address, email and contact numbers);
  • username and password, should you choose to create an account within our careers page;
  • information available within your CV and any other documents or supporting statements you submit to us;
  • educational details (e.g. educational history, qualifications, certificates) and career history (e.g. previous employment history, job titles, performance history, reason for leaving)
  • information about your current level of remuneration, including benefit entitlements (where appropriate, via submission of your most recent payslips and/or P60) and your aspirational level of remuneration;
  • information about any health issues or disabilities for which Procure Smart needs to make reasonable adjustments during the recruitment process and in any subsequent employment;
  • information about your entitlement to work in the UK, and where appropriate, information relating to your driving licence and any current endorsements held on your licence; and
  • information you may choose to voluntarily submit to us in connection with your application (e.g. information contained within a covering letter or supporting statement, information disclosed in telephone calls or during the interview process or information you volunteer regarding criminal history, family history or personal situations).
  • 1.2 Data we collect from other sources:
  • background check data, potentially including your criminal records history, employment history, educational history and/or remuneration history, from publicly available registers or databases, former employers and/or educational institutions (as allowed by local laws);
  • publicly available information from websites or social media, including information that you choose to voluntarily submit to us in connection with your application (e.g. when applying through LinkedIn);

(c)       information about you from Procure Smart employees who interview you and who may provide feedback about you (e.g. through our refer a friend scheme);

(d)      information about your performance or conduct from references, other Procure Smart employees, clients or service providers, or former employers you work with and/or or with whom you may have worked in the past who may provide feedback about you.

Procure Smart may collect this information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, and where appropriate, psychometric testing.

Where Procure Smart seek information from third parties, such as references, as either part of the recruitment process or once a job offer has been made, you will be notified of this and provide the relevant information to us in writing.

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


2            Why does Procure Smart process personal data?

Procure Smart must have a legal basis to process your personal data, in most cases the legal basis will be one or more of the following:

  • to process data in the recruitment process prior to entering into a contract with you and subsequently to enter into a contract with you.
  • to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.
  • to meet our legitimate interests, for example, to conduct our recruitment process efficiently and fairly or to manage applicants effectively during the recruitment process, and in keeping subsequent records of the process.
  • to respond to, and defend, any legal claims.

Processing data from job applicants allows Procure Smart to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

When we are required by local law to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfilment of our legal obligations and may impact our ability to employ you. You may withdraw your consent at any time by contacting us using the details at the end of this privacy statement.


3            Who has access to data?

During the recruitment process your information may be shared internally, this includes members of the recruitment team, HR and 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.

Procure Smart will not share your data with third parties, unless we seek previous employment references, as detailed above, and this information will be provided by you, in writing.

Procure Smart will not transfer your data outside the European Economic Area (EEA).


4            How does Procure Smart protect your data?

Procure Smart takes the security of your data seriously. We have 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 on this can be found in our Data Protection Policy (hyperlink).


5            How long does Procure Smart keep data?

We will keep your personal data until the position you have applied for has been filled, after which we will retain your personal data for a period of time that enables us to:

  • maintain business records for analysis, understanding market trends and/or audit purposes
  • comply with record retention requirements as required by local law
  • defend, establish, exercise or bring any existing or potential legal claims
  • ensure fraud detection and prevention
  • respond to any queries or complaints you may have
  • with your consent, suggest other roles that may be of interest to you

– if you agree to allow Procure Smart to keep your personal data on file, we will hold your data on file for a further 24 months for consideration for future employment opportunities. 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 employee file and retained by our HR department during your employment. The periods for which your data will be held will be provided to you in an employee privacy notice presented to you on commencement date.

By providing us with your personal information you certify that all the details you have given are true, complete and accurate, and acknowledge that if any information you have given is incorrect, incomplete or misleading, this may lead to withdrawal of any offer of employment or dismissal without notice if you have commenced work.


6            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 Procure Smart to change incorrect or incomplete data;
  • require Procure Smart to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data if you do not believe that Procure Smart has legitimate grounds to process your data.

If you would like to exercise any of these rights, please submit your request directly to the recruitment team via

If you have a concern regarding how we handle your personal data then we would request that you inform our Data Privacy Manager about it first so that we can work with you in an effort to resolve it.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to raise your concerns via the Information Commissioner’s Office.


7            What if you do not provide personal data?

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

This privacy statement relates specifically to the recruitment and selection process within Procure Smart.  We also have a full Privacy Policy.

[ September 2023 ]