Fair processing policy

For the purposes of this policy:


means a company that has engaged with Rethink Group in order to source services for a contractual assignment or to source an employee for a permanent vacancy.

Rethink Group

means the Rethink Group Limited and its subsidiary companies (Rethink Professional Services Limited t/a RTM, Digital Gurus Recruitment Limited, Rethink Recruitment Solutions Limited, TM Management Solutions Limited t/a Cognita Protects).

Data controller:

1 George Yard, London, EC3V9DF

Data protection officer:


As part of any recruitment process, Rethink Group 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 General Data Protection Regulation obligations.

What information does the organisation collect?

Rethink Group 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 about your current level of remuneration, including benefit entitlements;

whether or not you have a disability for which the organisation and /or the client needs to make reasonable adjustments during the recruitment process; and

information about your eligibility to work in the UK.

Rethink Group may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

If a client requires it as part of the recruitment process, with your consent Rethink Group may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.

Data will be stored on our CRM, Bullhorn and in other IT systems (including Rethink Group’s email system).

Why does Rethink Group process personal data?

Rethink Group needs to process data to take steps at your request in relation to work seeking purposes. We may also need to process your data to enter into a legally binding contract between yourself and your limited / umbrella company (contractors only).

In some cases, Rethink Group 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 the commencement of a contract assignment or a permanent role with a client of Rethink Group.

Rethink Group 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 Rethink Group to manage the recruitment process, assess and confirm a candidate’s suitability for the vacancy and decide whom to put forward for the vacancy. Rethink Group may also need to process data from job applicants to respond to and defend against legal claims.

Rethink Group may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. Rethink Group processes such information to carry out its obligations and exercise specific rights in relation to work seeking and employment activities.

For some of our clients, Rethink Group is obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment on behalf of our client.

If your application is unsuccessful, Rethink Group may keep your personal data on file in case there are future job opportunities for which you may be suited. Rethink Group will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

With your consent, your personal data will then only be shared with the client for the purpose of the recruitment process. This includes members of the client’s HR and recruitment teams, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT and compliance staff if access to the data is necessary for the performance of their roles.

If successful in obtaining a contract assignment or offer of a permanent role with one of our clients, only then will Rethink Group share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks if applicable and the Disclosure and Barring Service to obtain necessary criminal records checks, if applicable.

Your data will not be transferred to countries outside the European Economic Area (EEA) for work-seeking purposes without your specific consent.

How does Rethink Group protect data?

Rethink Group 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.

The organisation has the following relevant policies in place:

Acceptable Use Policy

Third Party Management Policy

Fair Processing Policy:

External Privacy Notice – Contract and Permanent Work Seekers

Internal Privacy Notice – Employees and Post-Employment

Data Breach Policy

Training and Awareness Policy

Data Retention and Destruction Policy

Access of data is governed and restricted by permissions controlled on the system which are determined by user authority and job function. All systems are routinely monitored and permissions are reviewed on a regular basis.

For how long does Rethink Group keep data?

If your application for a contract assignment or a permanent position is unsuccessful, Rethink Group will hold your personal data on file for 2 years from the last date of introduction to the client. If there is no further contact with anyone at Rethink Group by the end of that period, or if you withdraw your consent during this period, your data will be deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to the client if it is a permanent placement or to your Bullhorn record and retained during your contractual assignment if you have obtained a contract assignment through Rethink Group. If you become an employee of the Rethink Group or one of its subsidiaries, personal data gathered during the recruitment process will be used to raise a contract of employment and will be transferred to your employee record on the HR system.

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; and

object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact Data Protection Officer at dpo@rethinkgroupltd.com

If you believe that the organisation has not complied with your data protection rights, you can contact the Information Commissioner Office at www.ico.org.uk / 0303 123 1113.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Rethink Group 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.

Automated decision-making

Rethink Group does not perform any recruitment processes on automated decision-making systems.