Privacy Policy for Recruitment


Welcome to the Living Optic's privacy policy relating to our recruitment process. You are being a sent a copy of the privacy notice because you are applying to 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 exercise, and how long it will usually be retained for. It also provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are


Living Optics Limited (company number 12361188) is the controller and responsible for your personal data (collectively referred to as “Living Optics”, "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

  • Full name of legal entity: Living Optics Limited
  • Email address:
  • Postal address: Living Optics, 2nd Floor, 100 Park Drive, Milton Park, Abingdon, OX14 4RY, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 22 December 2022. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our recruitment portal may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, right to work visa, title and date of birth.
  • Contact Data includes home address, email address and telephone numbers.
  • Technical Data in relation to our recruitment portal, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use access our recruitment portal.
  • Profile Data includes your username and password used to access our recruitment portal.
  • Employment Data includes details of your employment history, information you have provided in your curriculum vitae and covering later, your qualifications, current level or remuneration (including any benefit entitlement), references and all answers to questions we might ask you relevant to the role.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

If you fail to provide information when requested which is necessary for us to consider your application (such as evidence of your qualifications or work history), we will not be able to process your application successfully.

How is your personal data collected?

We will collect information from you at different stages of the application process:

  • Application Stage. If you use our online recruitment portal, your details will be collected by our data processor, Greenhouse Software, Inc. on our behalf. You can also submit your application to us without using our online recruitment portal by emailing us at You may give us your Identity, Employment, Contact and Profile Data by filling in applications forms or by corresponding with us by post, phone, email or otherwise.
  • Assessments. We may ask you to attend an interview, virtually or on-site; complete tests; or any combination of these. Personal data will be generated at this stage by you and by us (for example, we will take notes during an interview).
  • Conditional Offers. If we decide to make you an offer of employment, this will be subject to us carrying out some pre-employment checks. We are legally required to confirm the identify of our staff and to make sure that all staff have a right to work in the United Kingdom. This might include providing us with:
  • proof of your right to work; and
  • proof of your qualifications.

We may also contact your referees to obtain references directly.

  • Automated technologies or interactions. As you interact with our recruitment portal, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties, including:
  • Contact, Identity and Employment Data from your previous employers, recruitment agencies and educational institutions.
  • Identity, Employment and Contact Data from publicly available sources, such as LinkedIn and Indeed.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data 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 relating to our hiring process;
  • help us improve our recruitment process;
  • contact you in the future if a similar vacancy comes up following completion of the recruitment process;
  • if you choose to register as a user of our recruitment portal, to administer your account and to improve, analyse and improve our recruitment portal; and
  • comply with our legal requirements.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

It is in our legitimate interests to use your personal data to decide whether to appoint you to the role and we have a business need to recruit candidates for this role. We also need to use your personal information to decide whether to enter into a contract of employment with you. Our processing of information about you to improve our recruitment portal is based on our legitimate interests of enhancing the effectiveness and user experience of our recruitment portal.

Disclosures of your personal data

We may share your personal data with the parties set out below, for the purposes set out above, with the following parties:

  • Your recruitment agency, if applicable.
  • Your named referees, if applicable.
  • Greenhouse Software, Inc. Greenhouse Software, Inc operates our recruitment portal and processes personal data uploaded to the recruitment portal on our behalf.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. 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 privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

How we use particularly sensitive information

You may voluntarily disclose your disability status with us during the recruitment process. We will use your particularly sensitive information regarding your disability status to consider whether we need to provide appropriate adjustments during the recruitment process. This might include, for example, considering whether adjustments need to be made during a test or interview. We will only use this information where we need to carry out our legal obligations or exercise rights in connection with employment.

International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and any applicable legal, regulatory or other requirements.

If your application is successful, personal information you have provided during the recruitment process will be kept in your employee file for the duration of your employment plus a further period of six years following the end of your employment.

If your application is unsuccessful, we will retain your personal information for six months from the date you applied for the 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 process in a fair and transparent way.

If you are already an employee and your application is unsuccessful, personal information you have provided during the application process will be kept in your employee file for the duration of your employment and for a further six-year period following the end of your employment.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in the future and we may wish to consider you for that role, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data
  • Request transfer of your personal data.

If you wish to exercise any of the rights set out above, please contact our data privacy manager

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



Legitimate Interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent. We may have sought your consent to retain your personal data in order to consider you for future vacancies. You have the right to withdraw consent for processing for that purpose at any time. To withdraw consent, please contact our data privacy manager. Once we have received notification that you have withdrawn consent, we will no longer process your personal data and, subject to our retention policy, we will dispose of your personal data securely.