Privacy Policy

This Recruitment Privacy Policy explains how Agilio Software (“Agilio”, “we”, “us”) collects, uses and protects personal data provided by individuals who apply for roles with us, or who create a candidate profile through our recruitment platform, Tribepad. This Policy should be read alongside our General Privacy Policy at agiliosoftware.com/legal-centre.

 

1. Who We Are

Agilio Software is a group of companies operating under brands including Agilio, Clarity, CODEplan, DenGro, Isopharm, myhrtoolkit, Patient Plan Direct and The Fresh. For recruitment purposes, Agilio Software Bidco Limited (company number 12242288) of 3rd Floor 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL, acts as the Data Controller for our shared recruitment function.

If you are offered a role, your employment contract will be with the specific Agilio group company advertising that vacancy (the “Hiring Entity”), which may be a different legal entity to Agilio Software Bidco Limited. The Hiring Entity will be identified in the vacancy details and/or your offer of employment, and will act as a data controller of your personal data for employment purposes from that point.

We have appointed a Data Protection Officer to oversee our compliance with data protection law. You can contact them at privacy@agiliosoftware.com.

 

2. The Personal Data We Collect

When you apply for a role or create a candidate profile, we may collect the following categories of personal data.

Information you provide directly

  • Your full name

  • Contact details (email address, telephone number, postal address)

  • Employment and career history

  • Education, qualifications and professional memberships

  • Your CV, cover letter and application responses

  • Right to work information, where relevant

  • Referee details and references, where applicable

 

Special category and criminal offence data

Where you choose to provide it, we may also collect diversity and equal opportunities information (for example, ethnicity, disability, religion or sexual orientation). This is ‘special category data’ under Article 9 UK GDPR. We collect it on a voluntary basis, for equal opportunities monitoring only, and rely on the substantial public interest (equality of opportunity monitoring) condition in Schedule 1, Part 2 of the Data Protection Act 2018, or your explicit consent. Providing this information is optional and has no bearing on your application.

Where a role requires a background or criminal record check (for example, a DBS check), we process information about unspent – and, where legally permitted, certain spent – criminal convictions under the condition in Schedule 1, Part 3 of the Data Protection Act 2018, limited to what the role genuinely requires.

 

Information collected later in the process

  • Interview notes and assessment outcomes

  • Results of skills-based or role-related assessments

  • Background checks where required (for example, DBS or regulatory checks)

  • Recordings of video interviews conducted via Microsoft Teams, where we ask for and you give your consent

 

3. How We Collect Your Data

Your personal data may be collected:

  • Through our online recruitment platform, Tribepad

  • Via email or telephone correspondence with our recruitment team

  • During interviews, including video or in-person interviews

  • From referees or background-check providers, where the law allows

 

4. How We Store Your Information

Candidate data is held within Tribepad, our Applicant Tracking System, which acts as a Data Processor on our behalf under a written data processing agreement. We ensure appropriate technical and organisational security measures are in place, and that access is limited to authorised Agilio personnel involved in recruitment.

 

5. How We Use Your Personal Data

We only use your personal data where we have a lawful basis to do so under UK GDPR (and, where applicable, EU GDPR). The table below sets out our purposes, the legal basis we rely on and, where that basis is legitimate interests, the specific interest we are pursuing.

Purpose of processing

Legal basis

Our legitimate interest (where applicable)

Assessing your suitability for the role you have applied for

Legitimate interests

Ensuring we select suitable candidates for interview and employment

AI-assisted CV parsing and skills matching to help recruiters shortlist candidates

Legitimate interests

Efficiently identifying candidates whose skills and experience match the role

Managing recruitment communications (arranging interviews, updating you on your application)

Legitimate interests

Keeping applicants informed and the process running efficiently

Conducting interviews and assessments, including recording video interviews with your consent

Consent (recordings); legitimate interests (the interview itself)

Making a fair, well-informed recruitment decision

Verifying your right to work and any regulatory or professional requirements

Legal obligation

–

Processing diversity and equal opportunities information you provide

Substantial public interest (equality monitoring) or explicit consent

Monitoring the fairness and inclusiveness of our recruitment process

Conducting DBS or other background checks where the role requires it

Legal obligation; legitimate interests

Meeting regulatory and safeguarding requirements

Contacting referees you have provided

Legitimate interests

Verifying your suitability and employment history

Keeping your details on file as part of a talent pool for future opportunities

Consent

–

Generating anonymised recruitment metrics (for example, diversity of applicant pools)

Legitimate interests

Understanding and improving the fairness of our recruitment process

 

6. Automated Screening and Automated Matching

Our recruitment platform may use automated screening questions (for example, right to work or minimum qualification checks) to filter applications. This is not automated decision-making that produces a legal or similarly significant effect on you: a human always reviews the outcome before any final recruitment decision is made. Our platform also automatically compares your profile and CV against the requirements of a role to generate a match score, and may use this to highlight strong matches to recruiters or flag applications that may need closer manual review. As with automated screening, this informs but does not replace human judgement: a recruiter always reviews this before any decision is made on your application. If you have concerns about how automated screening has been applied to your application, contact us at privacy@agiliosoftware.com and we will review it manually.

 

7. Who We Share Your Data With

We may share your personal data with:

  • Tribepad, as our recruitment platform provider

  • AI-assisted CV parsing and skills-matching providers engaged by Tribepad to support recruiter shortlisting

  • Other Agilio group companies involved in the hiring decision

  • Background screening providers (for example, DBS), where applicable

  • Professional advisers (legal, compliance, regulatory)

  • Public authorities, where we are legally required to share information

We do not sell candidate data, and do not use it for marketing purposes without your consent.

 

8. International Transfers

Where we, or Tribepad, transfer your personal data outside the UK, we ensure the transfer is protected by one of the following: a UK adequacy regulation confirming the destination country provides an adequate level of protection; appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses; or another lawful basis for transfer recognised under UK GDPR, such as your explicit consent.

Where we process personal data of candidates based in the EU – whether that processing is already taking place or begins in future – equivalent safeguards under the EU GDPR (such as the EU Standard Contractual Clauses) apply to any transfer of that data outside the European Economic Area.

 

9. How Long We Keep Your Data

We retain your recruitment data for as long as your candidate account remains active. If you have not logged into your account for 90 days, we will send you a reminder email; a further reminder follows after 120 days of inactivity, and your account and associated recruitment data will be automatically deleted after 180 days of continuous inactivity. You can ask us to delete your data sooner at any time by contacting privacy@agiliosoftware.com or by deleting your account via the Platform.

If your application is successful, we transfer relevant recruitment data to your employee record and retain it in line with our Employee Privacy Notice and applicable statutory retention periods (for example, tax and employment law record-keeping requirements).

10. Your Rights

Under data protection law, you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion of your data

  • Object to or restrict our processing of your data

  • Request data portability, in certain circumstances

  • Withdraw consent where processing is based on consent

To exercise your rights, contact privacy@agiliosoftware.com. We may need to verify your identity before responding.

If you are based in the EU, you also have the right to lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or the place of the alleged infringement, in addition to the UK Information Commissioner's Office.

 

11. Data Security

We use appropriate security measures to protect your personal data against unauthorised access, accidental loss, disclosure or misuse. Access is limited strictly to those involved in recruitment activities.

 

12. Complaints

If you have concerns about how we handle your data, please contact us first at privacy@agiliosoftware.com. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO): 0303 123 1113, ico.org.uk. Our group's lead supervisory authority in the EU is the Data Protection Commission of Ireland (dataprotection.ie), which you may also contact, in addition to your own local supervisory authority as set out in Section 10 above.

 

13. EU Representative

Agilio Software is established in the UK. For the purposes of Article 27 of the EU GDPR, we have appointed Agilio Software Netherlands BidCo B.V. as our representative in the EU.

 

14. Changes to This Policy

We may update this Recruitment Privacy Policy from time to time. The most recent version will always be available via our careers site or recruitment platform.