Privacy Notice
View the Affinity Water Employee Privacy Policy in an easy-to-read PDF format >
This Privacy Notice will help you understand how we use your personal data when you apply for employment with Affinity Water Limited.
We recommend that you read this privacy notice in full as it explains how and why we collect personal data about you, how and why it will be processed by us and our commitment to protecting your personal data.
1. ABOUT AFFINITY WATER
Affinity Water Limited ("Affinity Water", "We", "Our" or "Us") is a company registered in England and Wales under company number 02546950 whose registered office is at Tamblin Way, Hatfield, Hertfordshire AL10 9EZ.
We are registered as a data controller with the Information Commissioner's Office and our registration number is Z8926206.
We have a data protection officer ("DPO"). Contact details can be found in section 14 of this privacy notice.
2. ABOUT THIS PRIVACY NOTICE
This privacy notice applies to the personal data we collect about you during our recruitment process. We are committed to protecting your personal data in accordance with applicable data protection legislation including the UK GDPR, Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (together referred to as "Data Protection Legislation").
This privacy notice may change from time to time and, if it does, the up-to-date version will always be available on our website at https://www.affinitywater.co.uk. This privacy notice was last updated on 25th April 2025.
3. DEFINITION OF PERSONAL DATA
Personal data is any information that relates to an identified or identifiable living individual. This means that the individual is directly identifiable from that information or could be indirectly identified from that information in combination with other information.
4. PERSONAL DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity
- Name and Title
- Date of birth
- Gender
- Marital Status
- Passport number
- Driving license number
- Birth certificate
Contact
- Home address
- Telephone numbers
- Email address
- Next of kin and emergency contact details
Recruitment
- CV and application forms
- Interview notes and scoring
- Right to work check information
- Background checks such as qualifications, financial probity, sanctions and criminal record checks
- Employer references
Special Category Data
Health:
- Reasonable adjustments
- Disability information and/or long-term health conditions
Race
Religious or philosophical beliefs
Sexual orientation
Sex life
Personal data revealing Trade union membership
Criminal Conviction Data
- Details of criminal convictions and offences
5. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect personal data from and about you including through:
Direct interactions
We collect personal data from you during the application and interview process when you apply for a job with Affinity Water.
You do not have to provide the information we ask for, however if you don’t it may affect your application and our ability to assess your suitability for the role.
Information we receive from other sources
We may receive personal data about you from third parties who provide it to us. For example:
- Background checks performed during the recruitment process including checks in relation to criminal convictions, qualifications, financial probity, sanctions and references provided by current and/or former employers;
- CCTV which we may use for the purposes of ensuring safety and for the prevention and detection of crime;
- Where our employees are required by law, or otherwise, to undergo any medical assessments to consider and monitor their ability to fulfil the role in which they are employed;
- From recruitment agencies who source candidates on our behalf;
- From professional social media platforms such as LinkedIn.
6. PURPOSE AND LAWFUL BASIS OF PROCESSING YOUR PERSONAL DATA
We must have a legal basis for processing your personal data. We predominately process your personal data under the following legal grounds:
- When you have given us consent to do so for the specific purposes which we have told you about;
- If we enter into a contract with you or to take steps to enter into a contract with you;
- It is necessary in order to fulfil our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- The law permits or requires it.
We have set out in the following table the ways we commonly use personal data and which of the legal grounds we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
In some cases, we may use more than one legal basis for processing your personal data; this will depend on the specific purpose for which we are using your personal data.
Please contact us if you have any queries about the specific legal basis that we rely on for processing your personal data.
What we use your personal data for (purpose)
Type of data
Legal basis for processing (including basis of legitimate interest)
To assess your suitability for a role you have applied for, including an assessment of your skills and competencies, performance at interview and the uptake of references.
- Identity
- Contact
- Recruitment
- Necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Use of recruitment and social media platforms such as LinkedIn or agencies.
- Identity
- Contact
- Recruitment
- Necessary for our legitimate interests (to ensure we can source the best candidates for our roles).
To verify your identity and legal right to work in the UK.
- Identity
- Necessary for compliance with a legal obligation.
To meet any reasonable adjustments you may require during the recruitment process.
- Special Category data (health)
- Necessary for compliance with a legal obligation
- Necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment.
To assess your fitness for work.
- Special Category data (health)
- Necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
- Necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment.
To conduct a fair recruitment process.
- Identity
- Recruitment
- Special Category data (health)
- Necessary for our legitimate interests (to ensure we conduct a fair process)
- Necessary for compliance with a legal obligation
- Necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment.
To promote equality, diversity and inclusion (EDI) in our workplace, and to prevent and challenge discrimination or potentially discriminatory practices.
- Identity
- Special Category Data (health, racial or ethnic origin)
- Necessary for compliance with a legal obligation
- Processing is necessary for the purposes of our legitimate interests (to ensure Affinity Water is actively promoting EDI and preventing discrimination)
- Necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment
- Necessary for a substantial public interest (equality of opportunity or treatment and promotion or maintaining diversity at senior levels).
To perform background checks
- Identity
- Contact
- Recruitment
- Criminal Conviction
- Necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
- Necessary for compliance with a legal obligation
- Necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment.
Special Category Data
We do not need your consent if we use Special Category Data (see section 6 for details) in accordance with this privacy notice to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
7. AUTOMATED DECISION-MAKING (INCLUDING PROFILING)
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where it is necessary for entering into or to perform the contract with you and appropriate measures are in place to safeguard your rights;
- Where it is authorised by law; and
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of Special Category Data, we must have either your explicit written consent or it must be justified as a substantial public interest, and we must also put in place appropriate measures to safeguard your rights.
We may use automated profiling during recruitment for certain roles in the form of psychometric or personality profile testing. If this applies to you, you will always be provided with a copy of the final report and given the opportunity to comment on the results.
Except where required by law, you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have given you the opportunity to obtain human intervention, to express your point of view and to contest the decision.
8. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA
Personal data will only be handled by our trained recruitment and HR employees and the hiring manager who have a legitimate business need to access your personal data for the purposes set out in this privacy notice.
9. WHO ELSE WE MIGHT SHARE YOUR PERSONAL DATA WITH
Except as explained in this privacy notice, we will not share your personal data without your consent unless required to do so by law, where we have a legitimate interest in doing so, or to administer the working relationship with you.
We may share your personal data with you, and where we have obtained your consent to do so, your associates and your representatives.
We may disclose your personal data to the Police, Department for Work and Pensions, HMRC, UK Visas and Immigration, fraud prevention and investigation agencies and any other law enforcement agency to the extent necessary for purposes including preventing, investigating, detecting, and prosecuting criminal offences or where required to do so by law.
We may share your personal data with third-party service providers who assist us with administering our recruitment process. Any such third parties will only be permitted to use your personal data for specific purposes in accordance with our instructions and not for their own purposes.
If a business transfer or change of business ownership takes place or is envisaged, we may transfer your personal data to the new owner (or a prospective new owner). If this happens, we will inform you of this transfer.
10. HOW WE PROTECT YOUR PERSONAL DATA
We are committed to maintaining the privacy and security of the personal data you provide to us through the deployment of physical, technical and organisational security procedures designed to secure your personal data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.
Our recruitment data is held on secure systems and servers with access controls in place on a need-to-know basis.
We ensure all our staff are trained in data protection so they understand how they can help keep your personal data safe from unauthorised use and access.
Our sites are highly secured with physical access controls strictly implemented.
Where we have given you (or where you have chosen) a password which enables you to access our recruitment system, you are responsible for keeping this password confidential. You should not share this information with anyone.
Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us over the internet and you acknowledge that any transmission is at your own risk.
11. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE UK
Your personal data may be transferred to, and stored at, a destination outside the UK. When we transfer and store your personal data outside of the UK we will ensure that it is adequately protected by using appropriate safeguards as further detailed below.
Your personal data may be transferred to, and stored at, a destination outside the UK. When we transfer and store your personal data outside of the UK we will ensure that it is adequately protected by using appropriate safeguards as further detailed below.
Staff operating outside the UK who work for us, or one of our suppliers, may process your personal data. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services.
Where your personal data is transferred from the UK to a recipient outside the UK to a country not recognised by the UK as providing an adequate level of protection for personal data we will ensure the transfer shall be covered by the following:
- An International Data Transfer Agreement; and
- An international data transfer risk assessment of the receiving country; or
- In accordance with one of the derogations set out in the Data Protection Legislation.
12. HOW LONG WE KEEP YOUR PERSONAL DATA
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data are as follows:
We will retain your personal data in a form that permits identification only for as long as:
- we maintain an ongoing relationship with you; or
- your personal data is necessary in connection with the lawful purposes set out in this privacy notice for which we have a valid legal basis.
Plus, for the duration of:
- any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant); or
- an additional reasonable period following the end of such applicable limitation period.
In addition to the above:
- if any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.
Where your personal data is retained for claim limitation purposes or for a reasonable period thereafter, we will restrict our processing of your personal data to the storage of, and maintaining the security of, those personal data, except to the extent that those personal data need to be reviewed in connection with any legal claim or obligation under applicable law. After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.
Any third parties that we engage will keep your personal data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third-party providers, we will make sure that they securely delete or return your personal data to us.
We may retain personal data about you for statistical purposes. Where personal data is retained for statistical purposes, it will always be anonymised, meaning that you will not be identifiable from that data.
13. YOUR DATA RIGHTS
The legal rights you have in relation to your personal data are summarised below:
- Right to be informed - You have the right to be informed about the collection and use of your personal data, as covered by this privacy notice.
- Right of access – You have the right to access and receive a copy of your personal data, and other supplementary information (subject to a limited number of exemptions).
- Right to rectification – You have the right to have inaccurate personal data rectified, and incomplete personal data completed.
- Right to erasure – You have the right to request erasure of your personal data in certain circumstances.
- Right to restrict processing – You have the right to request restriction or suppression of your personal data.
- Right to data portability – Where we are processing your personal data based on your consent or for the performance of a contract you may request that we transfer your personal data to another organisation in a structured, commonly used machine-readable format. This only applies to personal data provided to us by you.
- Right to object – You have the absolute right to object to our processing of your personal data. The right to request we stop processing your personal data applies when we process your personal data based on a task carried out in the public interest or for our legitimate interests (or those of a third party). However, in these circumstances we may refuse to comply with your request if we can justify compelling legitimate grounds, or where the processing is for establishment, exercise or defense of legal claims.
- Rights related to automated decision-making including profiling – You have the right not to be subject to a decision based solely on automated processing (no human intervention), where the decision affects your legal status or rights or where the decision has a similarly significant effect. This type of processing is permitted where the decision is necessary for entry into or performance of a contract; is authorised by law; or based on your explicit consent. We can only use your Special Category Data for this type of processing where we have your explicit consent or if is necessary for reasons of substantial public interest.
If we are processing your personal data on the basis of consent you have the right to withdraw your consent at any time. If you decide to withdraw your consent, we will stop processing your personal data for that purpose unless there is another lawful basis we can rely on.
You can exercise your data rights free of charge. 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 improve our response to you.
We will comply with your request within one calendar month (from the time Affinity Water receives your request, or upon receipt of any additional information we have requested from you). Occasionally we may require more time to respond to your request if your request is complex. We will notify you within one month to inform you that we require additional time to comply with your request.
In exceptional circumstances where your request is manifestly unfounded or excessive, we may charge you for your request, or refuse to comply with your request. We will always inform you of the reasons for not being able to comply with your request.
For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the contact details provided below.
14. FURTHER INFORMATION
If you have any questions or concerns about how we handle your personal data, you can contact us by:
Post: FAO Data Protection Officer
Compliance & Ethics
Affinity Way Ltd
Tamblin Way
Hatfield
Hertfordshire
AL10 9EZ
Email: data.protection@affinitywater.co.uk
If you are unsatisfied with our response to any data protection issues you raise with us or our DPO, you have the right to make a complaint to the ICO. The ICO is the authority in the UK which is tasked with the protection of personal data and privacy and contact details can be found at https://ico.org.uk/global/contact-us/.
