Applicant Privacy Notice
👋 Introduction
At Genio we’re committed to being transparent and responsible in our approach to handling your personal data. This privacy notice explains what personal data we hold about you and how we collect and use it during and after the recruitment process. We also talk about the privacy rights that you have.
So if you’re applying to work for us as an employee, contractor, consultant, intern or volunteer, this page is for you. Have feedback or questions? Reach out to us at recruitment@genio.co.
For information on the personal data we collect when you visit our website or use our products and services, see our website and app privacy notice here.
✍️ Changes to this Privacy Notice
Although significant changes are rare, we’ll update this Privacy Notice when we need to so that it remains accurate and up-to-date. This could be when we make a change to our internal policies, or when legal requirements change.
We won’t ever make big changes without letting you know first and, where required, we’ll seek your consent. If we have your contact information in our system, we’ll send you an email about upcoming changes. To read previous versions of this privacy notice, please reach out to us at recruitment@genio.co.
❓Who is Genio and what do you do?
We're glad you asked! At Genio, we create, develop and sell amazing audio note-taking software products and services to individuals and organisations across the world. You can learn more about what we do here. Genio is made up of two legal entities:
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Sonocent Ltd - the parent company and Head Office, based in Leeds, UK
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Sonocent LLC - the subsidiary company, based in Florida, US
Our trading name is Genio. You can find full contact information for our offices here.
✅ Our approach
We won’t necessarily hold, use, or share all of the types of personal data described in this Privacy Notice in relation to you. The specific types of data about you that we will hold, use and share will depend on the role that you’re applying for, the nature of the recruitment process, how far you progress in the recruitment process, and your individual circumstances.
If your job application is successful, when you start in the role, we’ll provide you with another privacy notice that explains how we handle your personal data as someone who works for us.
⚖️ Data Controller
Genio is the Data Controller of the personal data we hold about you, which means that we make decisions about how we look after and use your data. That’s why it’s so important that we clearly explain how we handle your personal data in our privacy notice, so that you know what to expect from us.
🤔 What is Personal Data?
Any information that can be used to identify you, whether directly or indirectly. Some examples include your name, email address and contact telephone number.
💻 Personal Data and Special Category Data
UK Data protection law divides personal data into two categories: personal data and special category data. Any personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sexual life or sexual orientation, or biometric or genetic data that is used to identify an individual is known as special category data. (Anything else is just personal data).
🔑 What type of personal data do we hold about you and why?
At the initial stage of recruitment, we’ll collect, hold and use the following types of ordinary personal data about you:
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Information contained in your application/CV/covering letter, including your name, title, contact details, employment history, experience, skills, qualifications/training (including educational, vocational, driving licences where appropriate), as well as any other documents you send us as part of the application process.
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Publicly available information about you, such as your business social media presence
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Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests
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CCTV footage and visitor log information, where an in-person interview takes place at our offices
If you're shortlisted for a position, or you receive a conditional offer of employment, we may collect, hold and use the following additional types of ordinary personal data about you:
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Pre-employment check information, including references and verification of qualifications
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Right to work checks and related documents
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Referees’ names and contact details
We hold and use this personal data so that we can:
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Process your application and correspond with you about it
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Assess whether you have the required skills, experience, qualifications and training for a role within the company
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Make informed recruitment decisions
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Verify information provided by you
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Check and demonstrate that you have the legal right to work in the UK
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Keep appropriate records of our recruitment process and decisions
🧑⚖️ What are our legal grounds for using your personal data?
Under UK Data protection law we need to let you know the legal grounds on which we can hold and use your personal data:
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We need it to take steps, at your request, in order to enter into a contract with you (entry into a contract). By applying for a job with us you are effectively asking us to enter into a contract with you - whether this is an employment contract, a contract for services, or another type of contract.
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We need it to comply with a legal obligation (legal obligation), including: the obligation not to discriminate during our recruitment process, the obligation not to employ someone who does not have the legal right to work in the UK, and the obligation to check whether someone has any criminal convictions.
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It’s necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (legitimate interest). For example, it's in our legitimate interests to review and consider your personal data so that we can select the most appropriate candidate for the job.
☝️ What type of special category personal data do we hold about you, why, and on what legal grounds?
We will only collect, hold and use limited types of special category data about you during the recruitment process, as described below. Since special category data is more sensitive than ordinary personal data, we need to have an additional legal ground to collect, hold and use it. The additional legal grounds that we rely on are explained below for each type of special category data.
At the initial stages of recruitment, we may collect, hold and use the following special category data about you:
Adjustments for disability/medical conditions data
Information relevant to any request by you for adjustments to the recruitment process as a result of an underlying medical condition or disability.
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We use this information to enable us to carry out a fair, non-discriminatory recruitment process by considering/making reasonable adjustments to our process as appropriate. Our additional legal ground for using this information is that we need it to comply with a legal obligation/exercise a legal right in relation to employment – namely, the obligations not to discriminate, and to make reasonable adjustments to accommodate a disability.
At the later stages of recruitment, we may collect, hold and use the following special category data about you:
Criminal conviction data
Details of any criminal record which you disclose to us, or, we obtain through an enhanced background check
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We use this information to assess your legal or operational suitability for the job you’ve applied for. We’re entitled to carry out a criminal records check in order to make sure that there’s nothing in your criminal convictions history which makes you unsuitable for a job at Genio. Because certain roles require a high degree of trust and integrity given they involve dealing with our company funds, we’ll need to seek a basic disclosure of your criminal records history.
To learn more about the legal grounds we rely on to process your special category data, please read our Appropriate Policy Document.
📂 How do we collect your personal data?
You provide us with most of the personal data about you that we hold and use, in the application you submit, by completing any assessments, and during any interviews.
Some of the personal data we hold and use about you is generated from internal sources during the recruitment process. For example, the person interviewing you will score your suitability for the role and we record the reasons for decisions made about whether or not your application is successful.
Some of the personal data about you that we hold and use may come from external sources. For example if your application is made through a recruitment agency. If we offer you a role, we will carry out pre-employment checks, such as taking up references from past employers or education providers, and we may check your qualifications by contacting the awarding body. In some circumstances, we may ask the Home Office for information about your immigration status to verify your right to work in the UK. For some roles, we may also obtain information about you from publicly available sources, such as your LinkedIn profile or other media sources.
🔄 Who do we share your personal data with?
We'll start by saying that at Genio, we truly respect your privacy and would never sell or rent your personal data. There are scenarios where we may need to share your personal data internally within Genio, or, with a trusted third party for a specific reason (and then only the minimum amount necessary to do what we need to do). We provide more detail below:
✅ Your information may be shared internally for the purposes of the recruitment, apprenticeship, or work experience placement process. This includes sharing relevant information with members of our HR and recruitment team and shortlisting and interviewing panel members involved in the selection process. It may also include IT staff if access to the data is necessary for the performance of their job roles.
✅ We may also share your personal data with the following third-party service providers that handle your personal data on our behalf (our Data Processors):
Greenhouse.io
When you send a job application to us through our careers page, by email, via a third-party job board, or, via a recruitment agency, it will be uploaded to our applicant tracking system, Greenhouse. Similarly, if you send us your CV or information about yourself expressing your interest in working for us, we’ll upload your information to our talent pool in Greenhouse. Greenhouse is the software we use to manage applications including CVs and interview feedback and notes. Our legal ground for sharing your personal data with Greenhouse is that by submitting your application, you're consenting to sharing your information for the purpose of being considered for a job at Genio. You can withdraw your consent at any time by getting in contact with us at recruitment@genio.co.
Google Workspace
We use Google Mail, Calendar, Meet and Drive to communicate with you during the recruitment process, schedule interviews, share any documents relating to an interview (such as tasks or assessments), and carry out interviews by video-call. Our legal ground for sharing your personal data with Google Workspace tools is that it is in our legitimate interests to communicate with you, carry out interviews (whether in-person or online) and provide you with important information relating to your application.
Zoom and Microsoft Teams
We may use Zoom or MS Teams as alternative video-calling platforms for holding online interviews. Our legal ground for sharing your personal data with these platforms is that it is in our legitimate interests to carry out online interviews in line with our standard recruitment process.
Github
As part of the interview process for some technical roles, we may use Github, a cloud-based service for software development, to help us assess your coding skills. This means that you’ll be asked to submit a code-based task within Github before your interview or as part of your interview. Our legal ground for sharing your personal data with Github is that it’s in our legitimate interests to administer tasks and assessments relevant to the job,so that we can evaluate the technical ability of applicants.
Slack
In a scenario where you’ve submitted a technical task in Github, your task will be shared to a private channel in our internal instant messaging system, Slack, for peer review by specific Genio engineering staff. Our legal ground for sharing your personal data with Slack is that it’s in our legitimate interests to peer review code-based tasks in order to evaluate the technical ability of applicants.
Zincwork.com
As part of our recruitment process, we’ll share relevant information about you with Zinc, an automated pre-screening employment software, in order to carry out standard reference checks. On a case-by-case basis, we may also share relevant personal data with Zinc in order to carry out enhanced background checks. Our legal grounds for sharing this data are that it’s in our legitimate interests to verify your qualifications and work experience to ensure that they meet the job's requirements. It’s also in our legitimate interests to carry out checks to help identify potential issues that could impact our workplace safety and security.
Legal/professional advisers
We may share any personal data that’s relevant, where appropriate, with our legal and other professional advisers, in order to get legal or other professional advice about matters related to you, or in the course of dealing with legal disputes with you or other job applicants. Our legal grounds for sharing this personal data are that it's in our legitimate interests to seek advice to clarify our rights/obligations and appropriately defend ourselves from potential claims. It’s also necessary to comply with our legal obligations/exercise legal rights in the field of employment, as well as to make, exercise, or defend legal claims.
Home Office
We may share your right to work documentation with the Home Office, where necessary, so that we can verify your right to work in the UK. Our legal ground for sharing personal data with the Home Office is that we need to comply with our legal obligation not to employ someone who doesn’t have the right to work in the UK.
Apprenticeship Providers
We may share your personal data, where necessary, with apprenticeship providers in order to verify your eligibility for the scheme. Our legal ground for sharing this personal data is to comply with our legal obligation to share data with the apprenticeship provider under applicable education or apprenticeship laws. We also have a legitimate interest in sharing the data with the apprenticeship provider in order to support the apprenticeship application process.
🚫 What happens if you don’t provide us personal data
We’ll only ask you to provide personal data that we need to be able to make a decision about whether or not to offer you a job. If you decide not to provide particular information to us, we’ll have to make a decision on whether or not to offer you a job without that information. In some cases, this might result in us deciding not to hire you. For example, if we ask you to provide a certificate verifying a qualification and you decline, we’ll have to decide whether to hire you without that information. If you choose not to provide us with names of referees or references when asked, it’s likely that we wouldn’t offer you a job.
We also need to let you know that some of the personal data we’ll ask you to provide to us is required by law. So, for example, if you don’t provide us with the documentation we need to check your right to work in the UK, then we won’t be able to employ you by law. If you choose not to provide us with personal data when requested, we’ll tell you about the potential consequences of doing this at that time.
⌛ How long will we keep your personal data?
We’ll keep your personal data throughout the recruitment process.
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If your application is successful, when you start work for us you’ll be issued with our privacy notice for staff. This will include information about what personal data we keep from the recruitment process and how long we keep your personal data whilst you are working for us and after you have left.
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If your application is unsuccessful, we’ll keep your personal data for 12 months from the date we let you know of our decision. We keep data for this length of time so that we can keep in contact with you and let you know about other great vacancies that may be of interest to you. If you want us to delete your personal data from our systems, just let us know by sending an email to hr@genio.co. We also talk more about your data rights below.
Thirty days before the end of the 12-month period, we’ll send you an email asking for your consent for us to keep your personal data on file. If you confirm your consent, we’ll keep your data for a further 12 months and we’ll repeat the same process. If we don’t hear back from you by the time the 12-month period has ended, we’ll delete your personal data from our system.
There may also be situations where it's appropriate for us to keep specific items of your personal data for longer. We’ll base these decisions on the relevant circumstances and we’ll take into account the following:
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the amount, nature, and sensitivity of the personal data
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the risk of harm from unauthorised use or disclosure
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the purposes for which we process your personal data and how long we need the particular data to achieve these purposes
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how long the personal data is likely to remain accurate and up to date
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for how long the personal data might be relevant to possible future legal claims
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any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept.
In all cases, we won’t keep your personal data for longer than we need it for our legitimate purposes.
If during the period that we have your personal data on file, you’d like to apply for a live vacancy, please do reach out to us to let us know about this – particularly if it's not a close match with your previous experience or is in a different area of our business from a vacancy you applied for previously, as we might not otherwise realise that the vacancy would be of interest to you.
📃 References
If you provide us with your referees' information, we'll have to tell them what personal information of theirs you're sharing with us. You also need to give them our contact information and let them know they can reach out to us if they have any questions about how we'll use their personal data.
🤝 Your data rights
You have a number of legal rights relating to your personal data, which we outline below. Where we refer to “processing”, this could mean: collecting, using, storing, sharing (etc.) your personal data.
✅ The right to make a subject access request. You have the right to ask for information about how we use your personal data, get a copy of the personal data we have about you, and to make sure we're using it legally.
✅ The right to request that we correct incomplete or inaccurate personal data that we hold about you. Think we made an error? Let us know and we can fix this for you.
✅ The right to request that we delete or remove personal data that we hold about you. You can ask us to erase your personal data if there's no valid reason for us to keep using it. You also have this right if you've previously objected to us using your data (see the next paragraph).
✅ The right to object to our processing your personal data - You can say no to us using your personal data in situations where we’re relying on the legal ground of legitimate interest and we can't give you a good reason to keep using your data.
✅ The right to request that we restrict our processing of your personal data. This means you can ask us to stop using your personal data temporarily. You might do this if you want us to check if it's correct or why we're using it.
✅ The right to withdraw your consent to us using your personal data. If we're using your personal data based on your consent, and you decide to withdraw that consent, you can also ask us to delete or remove that data unless we have another valid reason to keep using it.
✅ The right to request that we transfer your personal data to another party. If you've given us personal data because it's necessary for a contract or you've given consent for us to use it, you can ask us for that data in a format that makes it easy to move to another service. This is also called the "right to data portability”.
If you’d like to carry out any of these rights, please contact us at recruitment@genio.co. We do need to let you know that these rights are not absolute, and in some situations we may refuse some, or all, of your requests - sorry about that.
We also need to let you know that 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. Details of how to contact the ICO can be found on their website at https://ico.org.uk.
Last updated 3 June 2025.