Who are we?

Pharmacosmos UK (Pharmacosmos) is a limited company registered in England and Wales whose registered office is The White Building, 6th Floor, 33 Kings Road, Reading, RG1 3AR. We take our Data Protection obligations very seriously and this notice gives you information about our approach to Data Protection legislation (UK General Data Protection Regulation, Data Protection Act 2018, Privacy & Electronic Communications Regulations (PECR)) and provides you with information about how we manage your personal data, during and after the application process with us.

Pharmacosmos as a Data Controller

For the purposes of this notice Pharmacosmos is the Data Controller. This means that we are responsible for deciding how we hold and use personal information about you.  We are required under Data Protection Legislation to notify you of the information contained in this privacy notice. 

This notice applies to anyone applying for a position with Pharmacosmos. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time, details of which are found at the end of this document. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.  

We kindly ask you not to include any special categories of personal data (health, racial or ethnic origin, trade union membership, religious beliefs, sexual orientation) in your job application, unless you believe such information is strictly relevant and necessary for us to assess your application. If you believe such data is strictly relevant and necessary for us to be able to process and assess your application, we will consider your forwarding of such data to us as your specific and explicit consent for us to process this data for the purposes set out in this privacy notice.

The personal data we collect

We collect personal data directly from you as follows: 

  • contact details such as name, title, address, telephone numbers, and personal email addresses,
  • personal information such as date of birth, gender (if included in CV),
  • copies of identification documents such as driving licence, passport,
  • evidence of how you meet the requirements of the job, including CVs and references,
  • evidence of your education, skills and work experience,
  • evidence of your right to work in the UK and immigration status,
  • information about your health, including any medical needs or conditions, in order for us to make reasonable adjustments during the recruitment process,
  • information relating to the interview process, personality tests or capability tests (where appropriate and relevant to the role),
  • background check information through reference checks, confirmation of employment and education, history and criminal record data (where appropriate and relevant to the role),
  • audio and video of you may be recorded for training and quality purposes 

Please note this list is not exhaustive but gives an indication of the data we collect.

How is your personal information collected?

We collect personal information about candidates through the application and recruitment process, either directly from candidates, or sometimes from an employment agency or background check provider.  We may sometimes collect additional information from third parties including former employers, credit reference agencies, Disclosure & Barring Service (DBS) or other background check agencies. Certain roles require a DBS check and we will inform you if this is the case prior to the check being undertaken. 

If you fail to provide personal information 
If you fail to provide certain information when requested, we may not be able to assess your capability for the position. This could affect your ability to be employed by Pharmacosmos. 

Purposes of our processing

We may use your personal information for the following purposes: 

  • make a decision about your recruitment or appointment, 
  • administering and processing your application,
  • check you are legally entitled to work in the UK,
  • conducting background checks including criminal convictions history (where appropriate dependent on the role),
  • communicating with you, other Pharmacosmos employees and third parties(e.g. referees, including former employers &external recruitment agencies),
  • complying with applicable laws, such as employment laws, and employment-related requirements,
  • responding to and complying with requests and legal demands from regulators or other authorities,
  • responding to requests from law enforcement agencies and the Courts. 

Please note this list is not exhaustive but gives an indication of the processing activities we undertake.

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Our legal basis for processing your data

We will only use your personal information when the law allows us to do so.  Most commonly we will use your personal information in accordance with the following conditions for processing: 

  • Consent (Article 6 (1a)) - We process your personal data based on your consent.
  • Contract(Article 6(1b)) – We process your personal data based on our contractual employment relationship. 
  • Legal obligation(Article 6 (1c)) – We process your personal data based on a law.
  • Legitimate interests (Article 6 (1f)) – We process your data for our legitimate interest and your interests and fundamental rights do not override those interests. 

Special category data is particularly sensitive personal information that requires higher levels of protection.  We need to have further justification for processing this type of personal information. We will use your personal information in accordance with the following conditions for processing: 

  • Explicit Consent (Article 9 (2a)) - We process your personal data based on your explicit consent in certain circumstances.
  • Employment, Social Security & Social Protection Law(Article 9 (2b)) – We process your personal data based on employment and social security law.
  • Legal Claims (Article 9 (2f)) – we will process your personal data in order to establish, exercise or defend legal claims. 

We will use relevant health information to consider whether we need to provide appropriate adjustments during the recruitment process.  We rely on the processing conditions in the Data Protection Act 2018 which relate to processing of special category data for employment, statutory and regulatory purposes. 

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations in respect of employment law and provided we do so in line with our Data Protection Policy. 

Who we share your data with?

We only share your information where we are strictly able to and only in accordance with Data Protection legislation. We may share your personal data in the following circumstances:

  • Within the Pharmacosmos Group,
  • With relevant recruitment agencies,
  • Where we are using contracted service partners for services such as IT hosting companies and IT services companies,
  • To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
  • To process your application for a DBS check where required for the role you have applied for,
  • To enforce or apply our Terms of Service or other agreements or to protect Pharmacosmos and its customers (including with other companies and organisations for the purposes of fraud protection and credit risk reduction),
  • To any other person with your consent to the disclosure. 

Finally we may share anonymised or aggregated data gathered in the normal course of the administration and good running of our business with third parties or service providers to enable greater analysis, improvements, industry or service related trends to be identified and action taken accordingly.

A list of third parties who we may share your data with can be obtained from our Data Protection Officer.

International Transfers

If your Personal Data is transferred to one of our affiliated companies or a third party located in a country outside the EU/EEA, Pharmacosmos will ensure that such transfer(s) will be carried out in accordance with the applicable data protection legislation, including the GDPR.

If your Personal Data is transferred to our affiliated companies outside the EU/EEA, without an adequacy decision, the transfer will be based on Pharmacosmos Intra-Group Agreements including the EU Commission’s Standard Contractual Clauses.

Transfers to third parties outside the EU/EEA, without an adequacy decision, will be safeguarded by ensuring that the third party enters into the EU Commission’s Standard Contractual Clauses and the UK ICO Addendum and the relevant assessments (TRA/TIA). 

Should such requirements change, we will review the obligations and amend this notice as appropriate. More information can be obtained by contacting our Data Protection Officer.

How long do we keep your data for?

We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our retention policy.

Your rights

It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes during your engagement with us.  

Your rights in connection with personal information
Under certain circumstances, by law you have the right to: 

Request access to your personal information (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

Request correction of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected. 

Request erasure of your personal information.  This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. 

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you. 

Request the transfer of your personal information to another party. 

Right relating to automated processing including profiling of your personal information. Pharmacosmos uses psychometric testing as part of our recruitment process, which is an automated decision-making tool. In accordance with GDPR, if you are unhappy with the outcome of an automated decision, you can ask us to review the results. Please contact our Data Protection Officer for further information in this respect. 

In the limited circumstances where you may have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.    

If you want to exercise any of your rights please contact our Data Protection Officer in writing. 

Data security

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to our personal information to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breaches and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.  

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. 

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with our Data Protection obligations.  If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at info@pharmacosmos.co.uk . 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 legislation. 

Changes to this privacy notice

From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. Pharmacosmos recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located below.

V.1.0 Initial creation 16/03/23 DPO 


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