Privacy Notice for UK and Europe Job Applicants



For the purposes of Data Protection legislation, including The General Data Protection Regulations Apollo Endosurgery UK Ltd is a Data Controller.

Apollo Endosurgery UK Limited collects and processes personal data relating to job applicants as part of its recruitment and selection procedures. The privacy & security of the personal data collected from job applicants is a priority to us and it is equally important to us that you understand how we handle this data and meet our data protection obligations.

What information does the organisation collect?

This notice provides detail about any personal information we collect and why we need this information.

Information collected & processed includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in the UK;

The organisation collects this information in a variety of ways. For example, data might be collected through CV’s or resumes, obtained from your passport or other identity documents, or collected through telephone, Skype and face to face interviews or other forms of assessment including online behavioural assessment tools.

The organisation will also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks for applicable roles. The organisation 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 securely on our IT systems (including email).

Why does the organisation process personal data?

The organisation needs to process data prior to entering into an employment contract with you.

In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work legally in certain countries before employment starts.

The organisation 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 the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied.

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

Who has access to data?

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

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.

Your data may be transferred outside the European Economic Area (EEA) to Apollo Endosurgery Inc our US parent company based in Austin, Texas. Data is transferred outside the EEA on the basis of Data Transfer Agreement between Apollo Endosurgery Inc. and Apollo Endosurgery UK Limited.

How does the organisation protect data?

The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data held securely and is not accessed except by our employees in the proper performance of their duties.

For how long does the organisation keep data?

If your application for employment is unsuccessful and if there is not a consent to keep your personal data on file in case there are future employment opportunities for which you may be suited, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of that period 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 our employee 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 the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
  • ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Sylvie Butt, HR Manager EMEA,

What if you do not provide personal data?

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


If you have any questions about the use of your personal data, please contact Jane Wright, Sr. Financial Controller or Sylvie Butt HR Manager EMEA.