Candidate Privacy Notice

Last updated: December 2025

This Candidate Privacy Notice explains how Sparta (“we”, “us”, “our”) collects, uses, shares, and retains your personal data when you apply for a role with us. It also explains your data protection rights and how you can exercise them.

This notice applies to all candidates applying for roles at Sparta entities located in the United Kingdom, Spain, Switzerland, the United Arab Emirates, the United States (Houston), and Singapore.

  1. What information we collect

We may collect and process the following categories of personal data:

1.1 Information you provide

  • CV/resumé and cover letter
  • Contact details (name, email, phone number, address)
  • Employment history, qualifications, skills
  • Salary expectations and work preferences
  • Responses to interview questions
  • Job application form data

1.2 Information generated during the recruitment process

  • Interview notes and assessment results
  • Information from recruiters or hiring managers
  • Communications between you and us
  • Video interview recordings (where applicable)

1.3 Information from third parties

  • Professional references
  • Background checks (where permitted by law and with your consent where required)
  • Right-to-work documentation
  • Publicly available professional profiles (e.g., LinkedIn)

1.4 Sensitive information (special category data)

We only collect sensitive data if necessary and permitted by law—for example, diversity information (voluntarily provided), or health information related to accommodations for interviews.

  1. Purposes for which we use your information

We use your personal data for the following purposes:

  • Managing and administering the recruitment process
  • Assessing your suitability for roles
  • Communicating with you about your application
  • Verifying your identity, qualifications, and right to work
  • Creating interview notes and evaluation summaries
  • Maintaining records for compliance with legal obligations (e.g., EEOC retention requirements in the US)
  • Adding you to our talent pool, only if you provide explicit consent
  • Improving our recruitment processes and analytics (in anonymous or aggregated form)

We do not use your data for automated decision-making that produces legal or significant effects without human review.

  1. Our legal bases for processing your data

Depending on the jurisdiction, we rely on:

3.1 Legitimate interests (UK, EU, Switzerland)

To evaluate candidates and manage recruitment processes.

3.2 Consent (UAE, Singapore; and globally for talent pools)

When required by local laws or when retaining your data for future roles.

3.3 Contractual necessity

Processing required to take steps at your request prior to entering an employment contract.

3.4 Legal obligations

Record-keeping obligations such as EEOC requirements in the US.

  1. How long we retain your data

We retain your personal data only for as long as necessary for the purposes outlined above. Our standard retention periods are:

  • 12 months for candidates who are not hired
  • Up to 24 months if you provide consent to be considered for future opportunities
  • As long as required by law (e.g., minimum 1 year in the US under EEOC rules)

You can withdraw your consent or request deletion at any time (see Section 7).

  1. Who we share your information with

We may share your data with:

  • Internal hiring managers and interviewers
  • Third-party recruitment agencies working on our behalf
  • Background check providers (where permitted)
  • Technology providers such as our Applicant Tracking System and assessment platforms
  • Professional advisers (legal, regulatory, or compliance)
  • Government authorities, if required by law

We do not sell candidate data.

Where data is transferred outside your jurisdiction (e.g., between Sparta group companies), we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.

  1. Data security

We implement appropriate technical and organisational measures to protect candidate data, including:

  • Access controls
  • Encryption of data in transit and at rest
  • Secure ATS systems
  • Staff confidentiality obligations
  • Regular audits and data-protection training
  1. Your data protection rights

Depending on your jurisdiction, you may have some or all of the following rights:

  • Access – to request a copy of your data
  • Correction – to update inaccurate information
  • Deletion – to request erasure of your data
  • Objection – to object to certain processing activities
  • Withdrawal of consent – where processing is based on your consent
  • Portability – to request transfer of your data (GDPR regions)

To exercise these rights, please contact us at:
people@spartacommodities.com

We will respond as required by applicable local laws.

  1. Automated decision-making

We do not make hiring decisions solely through automated means. If automated tools (e.g., CV screening algorithms) are used, results are reviewed by a human.

  1. Updates to this notice

We may update this privacy notice periodically. Any changes will be published on our website or made available through our recruitment channels.

  1. Contact us

For questions or requests regarding your data, you can contact:

Data Protection Officer
Sparta
Email: people@spartacommodities.com

 

You also have the right to raise concerns with your local data protection authority (e.g., UK ICO, Spanish AEPD, Swiss FDPIC, Singapore PDPC, UAE data office, US EEOC).