ROCKFISH GROUP LIMITED

EMPLOYEE AND APPLICANT PRIVACY NOTICE

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how the Rockfish Group collects and processes your personal data in connection with recruitment, hiring, onboarding, employment and related administration. This privacy notice explains how we collect and use personal data relating to individuals who apply for employment or other roles with us, whether applications are made directly or through a third-party recruitment platform or service provider. It also explains how we collect and use personal data relating to employees and workers during the course of employment, engagement, onboarding and related people management processes. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

Controller

The Rockfish Group is made up of different legal entities, details of which are set out above. This privacy notice is issued on behalf of the Rockfish Group, so when we mention "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Rockfish Group responsible for processing your data. We will let you know which entity will be the controller for your data when you apply for a role with us or commence employment or engagement. Rockfish Group Limited is the controller and responsible for this privacy notice. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Rockfish Group Limited

Name of data privacy manager: Mathew Prowse

Email address: dpo@therockfish.co.uk

Postal address: 5 South Embankment, Dartmouth, United Kingdom, TQ6 9BH

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 notice and your duty to inform us of changes

This version was last updated in October 2026.

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.

2. 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, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes home address, correspondence address, email address and telephone numbers.
Financial Data includes bank account and payment details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform and other technology on the devices you use to access our systems or platforms.
Profile Data includes your username and password, feedback, survey responses, interests, profiles and other profile information.
Usage Data includes information about how you use our website, recruitment systems, onboarding systems and internal systems.
Recruitment Data includes information contained in job applications, CVs, covering letters, employment history, qualifications, right to work information, references, interview notes, recruitment correspondence, onboarding information, and any other personal data provided during the recruitment process.
Employment Data includes role information, start date, employment terms, payroll information, attendance records, training records, performance information, disciplinary and grievance records, leave records, emergency contact details and other information created or used during your employment or engagement.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law if it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We may also collect limited special category data or other information where necessary for recruitment, onboarding, legal compliance, workplace adjustments, employment administration or related purposes. If we do so, we will process that information in accordance with applicable data protection law.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. This may include being unable to progress an application or onboarding process, employment process or related administration. We will notify you if this is the case at the relevant time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact, Financial, Recruitment and Employment Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for a role with us directly or through a recruitment process;
provide information during interviews or assessments;
provide right to work or onboarding documentation;
correspond with us during recruitment, onboarding or employment;
complete employment-related forms;
provide feedback; or
participate in internal surveys, reviews or people processes.

Recruitment processes

We may collect personal data from you when you apply for a role directly, through our website, through a recruitment platform, through a job board, or through another recruitment service provider. We may also collect information during interviews, assessments, onboarding and related recruitment administration. In some cases, personal data may also be collected where a candidate profile is created or updated within a recruitment system by us or on our behalf, rather than being completed directly by the candidate. Whether this happens will depend on how the recruitment process is operated in practice.

Employment administration

We may collect personal data from you and about you during your employment or engagement, including for payroll, benefits, scheduling, training, performance management, absence management, disciplinary and grievance processes, health and safety, compliance, internal administration and recordkeeping.

Automated technologies or interactions

As you interact with our website, recruitment systems or internal systems, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you use websites or systems employing our cookies.

Third parties or publicly available sources

We may receive personal data about you from various third parties as set out below:

Technical Data from analytics providers, advertising networks and search information providers;
Contact, Financial and other relevant data from providers of technical, payment and delivery services;
Identity and Contact Data from data brokers or aggregators;
Recruitment related personal data from recruitment platform providers, applicant tracking system providers, job boards, referees, background screening providers and other intermediaries involved in our recruitment processes;
Employment-related data from payroll providers, benefits providers, occupational health providers, training providers, regulators, professional advisers and other service providers involved in your employment or engagement.

4. 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 in the following circumstances:

where we need to take steps at your request before entering into a contract with you
where we need to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
where we need to comply with a legal or regulatory obligation.

We may also process special category data and criminal offence data where this is necessary for employment law obligations, assessing working capacity, equality monitoring, establishing or defending legal claims, safeguarding, or otherwise as permitted by data protection law. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data

Purpose / Activity	Type of data	Lawful basis for processing
To assess applications, shortlist candidates, arrange interviews and communicate with applicants	Identity, Contact, Recruitment Data	Taking steps at your request before entering into a contract; legitimate interests
To verify identity, right to work, qualifications, references and suitability for a role	Identity, Contact, Recruitment Data, Right to Work Data, Criminal Offence Data where applicable	Legal obligation; legitimate interests; employment law obligations
To make recruitment decisions and maintain recruitment records	Identity, Contact, Recruitment Data, Profile, Technical, Usage	Taking steps at your request before entering into a contract; legitimate interests; legal obligation
To issue contracts, onboard staff and set up employment records	Identity, Contact, Employment Data, Financial Data, Right to Work Data	Performance of a contract; legal obligation
To administer pay, tax, pension and benefits	Identity, Contact, Financial Data, Employment Data	Performance of a contract; legal obligation
To manage employment, duties, shifts, training, appraisals, promotion, conduct and grievances	Identity, Contact, Employment Data, Special Category Data where relevant	Performance of a contract; legitimate interests; legal obligation
To manage sickness, family leave, health and safety, workplace adjustments and occupational health	Identity, Contact, Employment Data, Special Category Data	Legal obligation; employment law obligations; legitimate interests
To monitor use of systems, ensure security and protect our business	Identity, Contact, Technical Data, Usage Data	Legitimate interests; legal obligation

We may use tools with artificial intelligence or machine learning functionality as part of our recruitment administration and related business processes, including to help organise applications, summarise information provided by candidates, or assist with matching or scoring functions. AI scoring may be available as a feature to summarise how well a candidate matches the job they applied for. The AI returns a score rather than making a decision on whether to progress the candidate.

Automated decision making

We do not ordinarily make decisions about individuals based solely on automated processing where those decisions produce legal effects or similarly significant effects. However, some recruitment or onboarding workflows may involve automated steps, such as reminders, status changes or process driven actions triggered by candidate activity or nonresponse within a specified period. Whether this occurs will depend on how the relevant workflows are configured. For example, if a candidate is automatically rejected because they have not completed an onboarding form within two weeks, that may amount to a decision based solely on automated processing. If we carry out solely automated decision making that has legal or similarly significant effects, we will provide additional information about that processing as required by applicable data protection law.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data where necessary with:

other companies in the Rockfish Group;
recruitment platform providers, applicant tracking system providers, onboarding providers and recruitment support or technology suppliers;
payroll, pension and benefits providers;
HR, IT and system administration service providers;
occupational health and medical advisers;
training and background screening providers;
professional advisers including lawyers, accountants, bankers, insurers and auditors;
HM Revenue & Customs, the Home Office, regulators, law enforcement bodies and other authorities where required; and
third parties in connection with a sale, transfer, merger or restructuring of our business. /li>

Where a third-party provider collects personal data directly from individuals through its own systems, that provider’s own privacy notice may also apply to its processing. We require third parties to respect the security of personal data and to process it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes unless they do so under their own lawful basis and privacy arrangements. Otherwise, they may only process your personal data on our instructions.

6. International transfers

Some of the third-party service providers we use are based outside the UK or the EEA, or may process, store or access personal information from countries outside the UK or the EEA. In addition, if emails or SMS messages are sent to candidates while they are outside the UK or the EEA, the content of those messages may leave the UK or the EEA. Where we transfer your personal information outside the UK, or engage a third-party service provider which does so on our behalf, we will take appropriate steps to ensure that the transfer is made in accordance with applicable data protection law and that appropriate safeguards are in place. This may include relying on an adequacy decision or regulations, approved standard contractual clauses, the UK International Data Transfer Agreement, the UK Addendum, binding corporate rules or another lawful transfer mechanism. Some third-party service providers may also process personal information for their own purposes, in which case their processing of personal information will be governed by their own privacy notices and applicable data protection obligations.

7. 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.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 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 the applicable legal requirements. In the case of recruitment and onboarding records, we will retain personal data for as long as reasonably necessary for recruitment, onboarding, recordkeeping, legal, regulatory and business administration purposes. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use this information without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

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 of your personal data;
request transfer of your personal data; and
withdraw consent.

If you wish to exercise any of these rights, please contact us.

No fee usually required

You will not usually have to pay a fee to access your personal data or exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.

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 exercise your other rights. 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 may take us longer than one 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.

10. Glossary

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties

Other companies in the Rockfish Group acting as joint controllers or processors and who are based in the UK.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

External Third Parties

service providers acting as processors who provide recruitment platform, onboarding, IT, payroll, pensions, benefits, communications, system administration and support services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

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