As part of any recruitment process, Code and Theory collects and processes personal data relating to job applicants. Code and Theory is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

When you apply for a position with Code and Theory, the following information will be collected about you:

Your name, address and contact details, including email address and telephone number;

Details of your qualifications, skills, experience and employment history; and

information about your authorization to work within the relevant jurisdiction.

Code and Theory may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

Code and Theory may also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks. Code and Theory will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does Code and Theory process personal data?

Code and Theory needs to process data to take steps at your request prior to offering a position of employment to you. It may also need to process your data to enter into a contract with you and for legal reasons, such as to ensure you have the proper authorizations to work within a specific location.

Code and Theory has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Code and Theory to manage the recruitment process, assess a candidate's suitability for employment and decide on whom to offer a job. Code and Theory may also need to process data from job applicants to respond to and defend against legal claims.

If your application is unsuccessful, Code and Theory may keep your personal data on file in case there are future employment opportunities for which you may be suited. Code and Theory will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

CVs that are sent speculatively may also be kept on file for future recruitment exercises.

Access to your data

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Code and Theory will not share your data with third parties, unless your application for employment is successful and sharing that information is necessary to the terms of your employment. For citizens of the European Union (“EU”), this means that data may be supplied to third-parties outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as mandated by the General Data Protection Regulation (“GDPR”) to facilitate transfer from the EU to other countries. By submitting your personal data, you’re agreeing to this transfer, storing or processing.

Protection of Data

Code and Theory takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Code and Theory keep data?

If your application for employment is unsuccessful, Code and Theory will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow Code and Theory to keep your personal data on file, Code and Theory will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period (or once you withdraw your consent), your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

  • Access and obtain a copy of your data on request;
  • Require Code and Theory to change incorrect or incomplete data;
  • Require Code and Theory to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • Object to the processing of your data where Code and Theory is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact

If you believe that Code and Theory has not complied with your data protection rights, you can complain to the supervisory authority.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Code and Theory during the recruitment process. However, if you do not provide the information, Code and Theory may not be able to process your application properly or at all.