Recruitment privacy
How we handle your details when you apply.
Effective 16 October 2026.
1. Who we are
We are FRESH PCS CONSULTANCY LTD trading as Fresh Tech ("we", "us", "our"). Our company registration number is 09296207 and our ICO registration is ZA136732. Our registered address is 28 Livesey Avenue, Ludlow, SY8 1HN. We are the data controller for the information described here.
This notice applies to personal information we receive about recruitment for the IT Support Engineer (2nd Line) role advertised on our careers page. Our general privacy policy covers website visitors and customers.
2. What we collect
Only what we need to decide whether to offer you the job. That is:
- Your CV and the few lines you send with it, including where you are based and your notice period.
- Your name and the contact details you give us (email address, phone number and, if you include it, postal address).
- Notes from the initial conversation and the practical session: what we asked, what you told us and our assessment against the role.
- Reasonable adjustment requests, so we can arrange them.
- If we make you a conditional offer: references, right-to-work evidence, driving licence and insurance details, and the outcome of a basic DBS check (see section 7).
We will not ask for a photograph, your date of birth or anything else that is not needed at that stage. We will not ask about your health; if you choose to tell us about a condition so we can arrange an adjustment, we use that only for the adjustment (see section 3). If you include extra details in your CV we will not use them.
3. Why we use it
To run the recruitment: reading applications, arranging conversations, assessing you against the role, making an offer and completing the checks that offer depends on. Where you ask for a reasonable adjustment, we use that information only to arrange the adjustment, and we keep it confidential within the hiring team.
4. Our lawful basis
For reading your application, talking to you, running the practical session, taking references and checking your driving licence and insurance, we rely on our legitimate interests under UK GDPR Article 6(1)(f): filling this role fairly, with no less intrusive way to assess suitability. Right-to-work checks are a legal obligation (Article 6(1)(c)).
If you tell us about a health condition so we can make a reasonable adjustment, we rely on our legal obligation under the Equality Act 2010 together with Article 9(2)(b) and Schedule 1 paragraph 1 of the Data Protection Act 2018.
For viewing a basic DBS certificate and keeping the minimal decision record, we rely on legitimate interests (Article 6(1)(f)) together with the Article 10 condition in Schedule 1 paragraphs 10 and 36 of the Data Protection Act 2018 (preventing or detecting unlawful acts). The reason is specific to this role: the engineer independently holds privileged access to customers' systems, data and premises, and a basic check provides limited verification of relevant unspent criminal history. We do not rely on your consent for any of this, because you could not freely withdraw it without ending your application, and because the check is a condition of the offer rather than something you agree to separately.
5. Who sees it
Applications and assessment notes are restricted to the hiring team, Sam and Matt, in a dedicated Microsoft 365 folder. Adjustment details and the DBS record are kept in a separate restricted folder that only Sam can open; Matt is told what adjustment to make, not why. Our Microsoft 365 administrators keep their ordinary administrative capability over the tenancy. Service providers supporting those systems, and advisers or authorities where necessary and lawful, may also process limited information. We will not share your application with customers.
6. Services we use
Applications come through a single LinkedIn job listing. LinkedIn processes your application as its own controller under the LinkedIn Privacy Policy, including how long it keeps your application on its platform, which is separate from our retention in section 9. Conversations and the practical session use Microsoft Teams, and we keep applications and notes in our Microsoft 365 tenancy, where Microsoft processes data for us under the Microsoft Products and Services Data Protection Addendum. We do not use any other recruitment platform, agency or screening tool.
Neither provider guarantees UK-only storage. Both may process data internationally using the legal transfer arrangements described in their terms, including contractual safeguards where applicable. Email the privacy contact in section 10 if you would like more detail.
7. Checks after a conditional offer
Any offer will be subject to references, right-to-work and relevant driving checks, plus a basic DBS check paid for by Fresh Tech. We'll arrange the DBS check after a conditional offer and consider any findings individually in relation to the role.
A basic DBS check shows unspent convictions and conditional cautions only. We will not ask you about spent convictions and we are not asking for a clean record. The check is a condition of the offer because of the independent privileged access this role carries (section 4). You apply for your own certificate and show it to Sam; we record only the date it was seen, the certificate reference, whether anything on it was considered, and the decision. We never keep a copy, photo or scan of the certificate. If something is disclosed, Sam talks it through with you before any decision, and the decision is about relevance to this role, never an automatic rejection. References, right-to-work and driving details are recorded only to the extent needed to confirm them.
8. What we will not do
- We will not use automated decision-making or profiling. Nobody is shortlisted, scored or rejected by software.
- We will not put your CV, your messages or our interview notes into AI tools, and we will not switch on AI ranking or summaries in LinkedIn or Microsoft for this hiring. LinkedIn and Microsoft run their own services under their own terms (section 6).
- We will not record, transcribe or use AI note-takers in conversations or the practical session, and we ask the same of you.
- We will not use your details for marketing or add you to any mailing list.
- We will not keep your CV in a talent pool for future roles. Any future arrangement would require a separate choice and stated retention period.
9. How long we keep it
If your application is unsuccessful, we keep it for six months after the recruitment closes so we can answer any questions about the decision, then Sam deletes it. The minimal DBS record and any adjustment detail are kept for the same period whether or not you join us, unless a specific, documented legal reason requires longer, and are then deleted. If you join us, only the employment records we need move into your staff file, which is covered by a separate staff privacy notice you will receive when you start; criminal record detail is not transferred to it as a matter of course.
10. Your rights
You have the right to:
- Ask for a copy of the personal information we hold about you.
- Ask us to correct information that is wrong or incomplete.
- Ask us to delete your information, or to stop using it, where we have no good reason to keep it.
- Object to how we are using your information.
- Complain to the Information Commissioner's Office if you are unhappy with how we have handled it.
To use any of these rights, or to ask a question about this notice, email hello@fresh-tech.uk. Please do not email a DBS certificate or medical details to this general address. Ask for Sam to arrange a private way to discuss an adjustment or sensitive query. If you need an accessible alternative to LinkedIn, ask us to arrange one. That address is for privacy and accessibility queries only; it is not a way to apply, and any unsolicited CV is not considered: we tell the sender, store nothing and delete it, unless a documented legal reason requires otherwise. You can contact the Information Commissioner's Office at ico.org.uk/make-a-complaint.
