Recruitment Privacy Policy

BADGEMORE PARK RECRUITMENT PRIVACY POLICY

For job applicants and prospective workers

Last updated: July 2026

  1.  Introduction

This Recruitment Privacy Notice explains how Badgemore Park collects, uses, stores and shares personal data about job applicants, prospective employees, workers, contractors and individuals applying for work with us. 

  1. Who we are

The data controller is:

Premier Golf Developments Limited trading as Badgemore Park
Company number: 03353424
Trading address: BadgemorE Park, Badgemore, Henley-on-Thames, Oxfordshire, RG9 4NR
Registered office: Ground Floor, Afon House, Worthing Road, Horsham, West Sussex, RH12 1TL
ICO registration number: ZA142960
Email: BusinessDirector@badgemorepark.com 

  1. Personal data we collect

We may collect and use the following information during recruitment:

  • name, address, email address and telephone number;
  • CV, covering letter and application form details;
  • employment history;
  • education, qualifications and training;
  • skills, experience and professional memberships;
  • interview notes and assessment results;
  • references;
  • right to work information;
  • identity documents;
  • salary expectations;
  • availability and notice period;
  • driving licence information, where relevant;
  • information about reasonable adjustments;
  • information provided during interviews or assessments;
  • correspondence with you;
  • recruitment decision records.

Where relevant and lawful, we may also collect special category data, such as health information relating to reasonable adjustments or equal opportunities monitoring.

We may process criminal offence data only where the role requires it or where another lawful basis applies.

  1. How we collect recruitment data

We may collect personal data:

  • directly from you;
  • from your CV, application form or covering letter;
  • from recruitment agencies;
  • from job boards;
  • from referees;
  • from former employers;
  • from professional bodies;
  • from right to work checks;
  • from publicly available professional profiles, where relevant and proportionate.
  1. Why we use recruitment data
Purpose Lawful basis
Assessing your application Legitimate interests / steps before entering into a contract
Communicating with you about recruitment Legitimate interests / steps before entering into a contract
Conducting interviews and assessments Legitimate interests
Checking qualifications, experience and suitability Legitimate interests / legal obligation where applicable
Taking up references Legitimate interests
Checking right to work Legal obligation
Considering reasonable adjustments Legal obligation / special category employment condition
Making recruitment decisions Legitimate interests / steps before entering into a contract
Keeping recruitment records Legitimate interests / legal obligation
Defending legal claims Legitimate interests / legal obligation
Equal opportunities monitoring Legitimate interests / substantial public interest where applicable
  1. Special category data

We may process special category data during recruitment where necessary and lawful. This may include health information where you request reasonable adjustments or where relevant to your ability to carry out a role safely.

We may also collect equal opportunities information. Where collected, this will be used for monitoring and reporting and will not usually be used to make recruitment decisions.

  1. References

We may contact referees provided by you. Normally, we will only contact referees after an offer has been made, unless we tell you otherwise or you agree to earlier contact.

  1. Right to work checks

We are legally required to check that successful applicants have the right to work in the UK. We may ask you to provide identity and right to work documents before employment starts.

  1. Criminal record checks

We will only request criminal record information or DBS checks where this is lawful, necessary and relevant to the role.

  1. Who we share recruitment data with

We may share recruitment data with:

  • recruitment agencies;
  • HR software providers;
  • job boards;
  • referees;
  • professional advisers;
  • occupational health providers, where relevant;
  • background check providers, where relevant;
  • government bodies where required;
  • legal advisers, insurers, courts or tribunals where necessary.

Where third parties process data on our behalf, we require them to protect it appropriately.

  1. International transfers

Some recruitment systems or suppliers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will ensure appropriate safeguards are in place, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

  1. How long we keep recruitment data
Type of applicant data Typical retention period
Unsuccessful applications Usually 6–12 months after the recruitment process ends
Interview notes and assessment records Usually 6–12 months
Speculative applications Usually 6–12 months
Talent pool records Only with consent, normally up to 12 months
Successful applicant records Transferred to personnel file and retained in line with the Staff Privacy Notice
Right to work checks for successful applicants Employment period plus at least 2 years
Legal claim or dispute records As long as necessary for the claim or dispute

 

  1. Automated decision-making

We do not usually make recruitment decisions based solely on automated decision-making.

If this changes, we will provide appropriate information about the logic involved, the significance of the processing and your rights.

  1. Security

We take appropriate steps to protect recruitment data against unauthorised access, loss, misuse or disclosure.

Access to recruitment data is restricted to those who need it for recruitment, HR, management, legal or compliance purposes.

  1. Your rights

You may have the following rights:

  • right of access;
  • right to rectification;
  • right to erasure;
  • right to restriction;
  • right to object;
  • right to data portability;
  • right to withdraw consent where processing is based on consent;
  • rights relating to automated decision-making and profiling.

These rights are not absolute and may be subject to legal exemptions.

To exercise your rights, contact:

BusinessDirector@badgemorepark.com

  1. Complaints

If you have concerns about how we process your personal data, please contact us first.

We will acknowledge data protection complaints within 30 days and respond without undue delay.

You also have the right to complain to the Information Commissioner’s Office.

Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113

  1. Changes to this notice

We may update this Recruitment Privacy Notice from time to time. The latest version will be made available to applicants where appropriate.