What is the purpose of this document?
Oxford Endovascular Limited (we, us or our) is a data controller in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You are provided with this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment process, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
• The information you have provided to us in your curriculum vitae and covering letter.
• The information you have provided as part of the application form, including name, title, nationality, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
• Eligibility to work in the UK, for example, driving licence / passport details.
• Any information you provide to us during an interview.
• Any other information included as part of the application process, such as test/task result.
We may also collect, store and use the following special categories of personal data / more sensitive personal information:
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
• You, the candidate.
• Our preferred and authorised recruitment agency partners, from which we collect the following categories of data: Name, title, nationality, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, and any information you have provided to the recruitment agency.
• Disclosure and Barring Service in respect of criminal convictions.
• Your named referees, from whom we collect the following categories of data: Employment History and sickness records.
• Publicly accessible data from third parties such as LinkedIn, Glassdoor, Twitter, Facebook, Instagram.
How we will use information about you We will use the personal information we collect about you to:
• Assess your skills, qualifications, and suitability for the role.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract with you.
Having received your CV and covering letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview/s (including any test / task results) to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and may carry out a criminal record check where applicable before confirming your appointment.
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information (also known as special categories of personal data)
We will use your particularly sensitive personal information in the following ways:
• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
If we process sensitive personal information about you, we need to have further justification for collecting, storing and using this type of personal information. We also need to have in place an appropriate policy document (this privacy notice is our appropriate policy document) and are required by law to maintain safeguards when processing such data. We may process sensitive personal information in the following circumstances:
• In limited circumstances, with your explicit written consent.
• Where we need to carry out obligations or exercise rights in connection with your potential employment with us. This is our appropriate policy document explaining safeguards which we are required by law to maintain when processing such data and this processing is justified on the basis of paragraph 1 (Employment, social security and social protection) of Schedule 1 of the Data Protection Act 2018.
• Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme or preventing or detecting an unlawful act. This Privacy Notice is our appropriate policy document explaining safeguards which we are required by law to maintain when processing such data and this processing is justified on the basis of paragraph 8 (Equal opportunity of treatment), 9 (Racial and ethnic diversity at senior levels of organisations) and/or 10 (Preventing or detecting unlawful acts) of Schedule 1 of the Data Protection Act 2018.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of consenting, or where you have already made the information public.
We have put in place procedures to ensure that we:
• check the accuracy of the sensitive personal information we collect and correct it where
• record the source of sensitive personal information we collect;
• minimise the amount of sensitive personal information we collect; and
• periodically review any sensitive personal information we have obtained so that any such
information can be deleted when it is no longer required.
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory) and it is appropriate given the nature of the role and where we are legally able to do so. In which case, we are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
• We may, from time to time be required by our clients to carry out criminal record checks for those carrying out roles exposed to sensitive data.
Where appropriate, we will collect information about criminal convictions as part of the recruitment process. This is our appropriate policy document and we have procedures in place (as set out above), which we are required by law to maintain when processing such data.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so (taking into account your interests or fundamental rights and freedoms where legally required). We may approach you for your consent for this in some circumstances, and where we do so we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. It is not a condition of your contract with us that you agree to any requests for consent from us.
We are allowed to use and retain your personal information in that way where we have a legitimate interest to carry out our statutory and contractual obligations.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
We may share your personal data with the following third parties, but only for the purposes of processing your application.
• Vendors and service providers – we provide information to vendors and service providers who support our respective operations, such as by providing IT services
• Professional advisers and other external parties – including lawyers, bankers, auditors and insurers who provide professional services.
• Legal, supervisory, and regulatory authorities – we may share information with legal, supervisory and regulatory authorities and any government agencies and law enforcement bodies, or in response to a valid subpoena or legal process served by a third party, to comply with our legal obligations; protect the rights and property of Oxford Endovascular and our employees; and to detect and respond to suspected illegal activity and threats to the safety of any person, systems or services.
• Shareholders – we provide information to shareholders as part of our reporting activities.
• In connection with any restructuring or investment – we provide information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who may choose (or contemplate) to invest in us. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
• Funds – we provide information to funds managed by shareholders of group companies.
• Group companies – we provide information to members of the same group as our shareholders, as well as their professional advisers.
All our third-party service providers, shareholders, funds and group companies are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.]
Transfer of personal information outside the UK
We may transfer your personal data outside the UK (including to Mauritius, Cayman Islands, British Virgin Islands, China and the United States of America, where some of our shareholders or service providers are based), in which case we take measures to implement appropriate safeguards to protect your data. We may also transfer your personal data to countries (including Jersey where one of our shareholders is based or a member state of the EEA) that have been deemed to provide an adequate level of protection for personal data.
If you would like further information on the specific mechanism used by us when transferring your personal data out of the UK, please email
Your legal rights
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing at email@example.com.
Right to withdraw consent. When you applied for this role, you provided consent on your application date to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please email firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
Right to complain. If you have a complaint relating our processing of your personal data, we would welcome the opportunity to deal with your concerns before you approach a regulator. In order to raise your concern, please email email@example.com. You also have the right to make a complaint at any time to your local data protection authority if you are in the UK or the EEA. If you are in the UK, the Information Commissioner’s Office is the statutory regulator. For contact and other details see: https://ico.org.uk/ICO.
In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.
By applying for a role with Oxford Endovascular Limited, you knowledge that you have read and understood this privacy notice.
Status of this notice
This privacy notice will not form part of any contract with you and does not create contractual rights or obligations. It may be amended by us at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
This is our appropriate policy document setting out how we will protect special categories of personal data and (where applicable) criminal offence data. This meets the requirement of the Data Protection Act 2018 that an appropriate policy document be in place where processing special categories of personal data and criminal offence data in certain circumstances.