Our Policies

Privacy Policy

Company Name:

Moxie People (‘the Company’)

Contact Details:

5th Floor, 1 Central Square, Cardiff, CF101FS

02921 602 111



Privacy Notice
(including for use on the company website)


Data protection


September 2020



Moxie People is a recruitment business which provides work-finding services to its clients and work-seekers. We must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Moxie People acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. We must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement.

At all times we will comply with current data protection laws.


  • Personal Data – Collection & Use
    1. Purpose of processing and legal basis
  • Legitimate interest
  • Statutory/contractual requirement
  • Recipients of data
  • Information to be provided when data is not collected directly from the data subject
    1. Categories of data
  • Sources of data
  • Data retention
  • Your rights
  • Cookies
  • Log files
  • Links to external sites
  • Sale of the business
  • Data security
  • Changes to this privacy statement
  • Complaints or queries
  • Personal Data – Collection & Use
  • Purpose of processing and legal basis
  • Consent
  • Legitimate interest
  • Legal obligation
  • Contractual obligation
  • Legitimate Interest
  • Statutory/Contractual Requirement
  • Recipient/s of Data

Moxie People will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

Where Moxie People has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where Moxie People has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

An existing copy of your CV stored on our records matches a relevant role

You have submitted a CV/job application to Moxie People via our website or an external job board

You have emailed a copy of your CV to a Moxie People employee

An employee of Moxie People has identified you as a relevant business contact and has obtained your details on LinkedIn, a company website or other publicly available source in order to further a business relationship

An employee of Moxie People has obtained your personal details / a publicly available copy of your CV from a job board website/online CV database or social networking website

A colleague/friend/associate has sent us a copy of your CV as a referral/recommendation for a relevant role

If you no longer wish Moxie People to store and process your CV or other personal data, please send a written request via email to gdpr@moxiepeople.com

Moxie People has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.).

Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. Failure to provide Moxie People with the required personal data could result in:

Any offer of employment (temporary, contract or permanent) being rescinded due to insufficient information

Payment for work completed could be withheld if necessary, where sufficient details are not provided

Some companies conduct extensive background checks. Failure to provide the necessary information may result in an offer being rescinded.

Moxie People will process your personal data and/or sensitive personal data with the following recipients:

  • Our Clients (Employers whom we may introduce or supply you to)
  • Former employers whom we may seek references from
  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Trusted third parties where we have retained them to provide services that you or our clients have requested, such as training and criminal reference checking services (as required).
  • Information to be provided when data is not collected directly from the data subject
  • a. Personal data:

Categories of Data

Moxie People has collected the following personal data on you:

  • Name, address, mobile no., email
  • Nationality (through right to work check)
  • Date of Birth
  • National insurance Number (required for all contractors and may be required for candidates that are placed in a permanent position)
  • Identification documents (e.g. driving license, passport, birth certificate, bank statement, utility bill)
  • b. Sensitive personal data:
  • Health information including whether you have disability/health conditions
  • Criminal conviction / DBS Certificate

Source of the personal data:

The Company sourced your personal data/sensitive personal data from:

  • Job boards, LinkedIn, Facebook, Twitter
  • A former employer
  • A referee whose details you previously provided to us
  • Software providers who we use to support our services including [list]
  • Cookies listed in section 7
  • A friend, former colleague or associate
  • Data Retention
  • Your Rights
  • Cookies
  • Log Files
  • Links to external websites
  • Sale of Business
  • Data Security
  • Changes to this Privacy Statement
  • Complaints or Queries


This Website collects some Personal Data from its Users. View the personal data processed and using the following services.

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

Please be aware that you have the following data protection rights:

The right to be informed about the personal data that Moxie People processes on you;

The right of access to the personal data the Moxie People processes on you;

The right to rectification of your personal data;

The right to erasure of your personal data in certain circumstances;

The right to restrict processing of your personal data;

The right to data portability in certain circumstances;

The right to object to the processing of your personal data that was based on a public or legitimate interest;

The right not to be subjected to automated decision making and profiling; and

The right to withdraw consent at any time.

Where you have consented to Moxie People processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting gdpr@moxiepeople.com

Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where Moxie People will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that Moxie People processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Our website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site, we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.

If the Moxie People is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

The Company takes every precaution to protect our users’ information.

Only employees who need the information to perform a specific job are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.

If you wish to make an enquiry or complaint about our privacy policy, please email hello@moxiepeople.com

You also have the right to raise concerns with Information Commissioner’s Office at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.