Upway (“we”, “us”) are committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Upway.
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions
Where you apply for an opportunity posted by us, these Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice which is available on
Your Personal Information
Information we collect from you
We collect and process some or all of the following types of information from you:
Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method.
In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience and any information relating to your employment history, skills and experience that you provide to us.
If you contact us, we may keep a record of that correspondence.
Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.
Information we collect from other sources
Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.
Uses made of your information
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business.
Purposes of processing
We use information held about you in the following ways:
To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that we receive from you with information obtained from third party data providers.
To find appropriate candidates to fill our job openings.
To help Pinpoint improve their services.
Automated decision making / profiling
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.
How we store your personal data
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
Where we store your personal data
The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.
How long we keep your personal data
We retain all candidate data for a period of 48 months from the time of application. Your personal information will be deleted on one of the following occurrences:
Deletion of your personal information by you via the Manage Your Data tool or
Receipt of a written request by you to us.
Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
require us to correct any mistakes in your information which we hold
request the erasure of personal data concerning you in certain situations
request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
If you would like to exercise any of those rights, please either:
utilise the Manage Your Data tool provided or
contact us using our contact details below, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.