Candidate Privacy Notice

Effective date: 7 September 2026

Who this notice applies to: Candidates applying for roles with BW ESS Limited or any of its subsidiaries

Privacy queries and data subject requests: dpo@bw-ess.com

Data Protection Officer: Justine Fox

1. Purpose of this notice

This Candidate Privacy Notice explains how BW ESS Limited and its subsidiaries collect, use, store, share and protect personal data about individuals who apply for roles with us, are referred to us, are submitted by recruitment agencies or are otherwise considered for recruitment opportunities.

In this notice, “BW ESS”, “we”, “us” or “our” refers to BW ESS Limited and the relevant BW ESS group company or companies involved in the recruitment process for the role you apply for.

This notice applies to personal data processed in connection with our recruitment activities, including through the applicant tracking system and hiring platform provided by Greenhouse Software, Inc. (“Greenhouse”).

2. BW ESS group structure and controller responsibility

BW ESS Limited is the top company of the BW ESS group. BW ESS Management GmbH is an indirectly wholly owned subsidiary of BW ESS Limited and is the contracting entity for the Greenhouse applicant tracking system used by the BW ESS group. Greenhouse processes personal data on behalf of BW ESS in accordance with BW ESS’ documented instructions and the applicable data processing agreement.

The BW ESS group company that is recruiting for the role you apply for will be the controller of your personal data for that recruitment process, unless we tell you otherwise. This will usually be the BW ESS group company identified in the job advertisement, recruitment correspondence or offer documentation. This means that the relevant BW ESS group company decides why and how your personal data is processed in connection with that role.

In some cases, more than one BW ESS group company may be involved in the recruitment process. For example, BW ESS group companies may share recruitment administration, HR, legal, compliance, IT, finance, management or governance support. Where this happens, the relevant BW ESS group companies may process your personal data for the purposes described in this notice.

3. What recruitment platform do we use?

BW ESS uses Greenhouse to support recruitment across the BW ESS group, including in the United Kingdom, the European Economic Area (including Germany, Spain and Italy), Switzerland and Australia. The platform may also be used for recruitment in additional countries where BW ESS conducts recruitment activity in the future.

The platform helps us keep recruitment information in one place, track applicants from application through to offer, coordinate interviews, document recruitment decisions and manage recruitment reporting.

BW ESS uses the platform for recruitment purposes only. It is not used for onboarding, internal mobility or performance reviews.

4. What personal data we collect and use and why

We may collect and process the following categories of personal data about you, depending on the role you apply for and the stage of the recruitment process. We process this personal data for the following reasons and in reliance on the following legal grounds:

Personal Data	Purpose	Lawful basis
Identification and contact details (name, email address, phone number, postal address).	Communicating with you about the recruitment process; receiving and managing your application; scheduling interviews.	Legitimate interests (to manage the recruitment process and communicate with candidates).
Application information (CV, cover letter, employment history, education history, qualifications, professional memberships, skills, experience, work samples, assessment submissions and LinkedIn profile).	Reviewing and assessing your suitability for the role; comparing candidates.	Legitimate interests (to recruit suitable and qualified candidates).
Recruitment assessment information (interview notes, scorecards, assessment results, hiring manager feedback and recruitment decisions).	Conducting interviews and assessments; evaluating candidates; making hiring decisions.	Legitimate interests (to make informed hiring decisions).
Compensation and role-related information (salary expectations, notice period, role and location preferences, availability).	Preparing employment offers and contracts; negotiating terms.	Legitimate interests (to ensure an efficient hiring process). Steps prior to entering into a contract (to take steps necessary to enter into an employment contract at your request).
Reference information (feedback and opinions from your referees).	Verifying candidate information; assessing suitability.	Legitimate interests (to verify the accuracy of information provided and assess candidate suitability).
Communication records (emails, messages and other correspondence during the recruitment process).	Managing the recruitment process; maintaining records.	Legitimate interests (to manage recruitment and maintain appropriate records).
Right to work and immigration information (work authorisation details, immigration status, visa or work permit information, nationality, date of birth, passport or other identification document details, National Insurance number or similar information and any other information required to assess your eligibility to work in the relevant country or support a visa, work permit or immigration application).	Verifying eligibility to work; supporting visa or immigration applications; complying with legal, regulatory or governance requirements.	Legal obligation (to comply with immigration and employment law requirements).
Technical and account information for the Greenhouse platform (account details, login activity, permission levels, audit information).	Operating and securing the recruitment platform; managing user access; maintaining audit records.	Legitimate interests (to ensure the security and proper operation of the recruitment platform).
Any other information you choose to provide(attachments, responses to application questions, correspondence).	Assessing your application; responding to your queries; considering any additional information relevant to the role.	Legitimate interests (to consider all relevant information provided by candidates).
Recruitment process data and analytics.	Improving the efficiency, consistency and fairness of our recruitment processes; generating recruitment-related analytics and reporting	Legitimate interests (to understand the effectiveness of our recruitment processes and improve them over time)
Voluntary diversity information (gender, racial or ethnic origin, where voluntarily provided).	Monitoring diversity and inclusion in recruitment.	Explicit consent. Collected on a voluntary basis only.
Health, disability or biometric information (where required for visa, immigration or right to work processes).	Supporting visa, work permit or immigration applications where required by relevant authorities or immigration advisers	Legal obligation or reasons of substantial public interest. Collected only where required by applicable immigration or employment law.
Information relevant to reasonable adjustments (disability, health conditions or other circumstances you choose to disclose).	Considering and implementing reasonable adjustments, accommodations or other support during the recruitment process.	Legitimate interests (to provide an accessible and fair recruitment process); where special category data is processed, due to a legal obligation or explicit consent.

5. Special category personal data and other sensitive information

Some personal data is treated as more sensitive under applicable data protection laws. This may include “special category personal data” under European or UK data protection laws, “sensitive personal data” or “sensitive information” under other applicable laws, including Australian privacy law. This may include information about racial or ethnic origin, health, disability, religious beliefs, trade union membership, sexual orientation, biometric data or genetic data.

As set out in Section 4 above, BW ESS does not generally require special category personal data or sensitive information for the recruitment process. However, we may collect or process certain sensitive information where this is necessary or appropriate as described in Section 4 above. Where we process special category personal data, sensitive personal data or other sensitive information, we will only do so where permitted by applicable law and where appropriate safeguards are in place.

We do not use the recruitment platform to conduct criminal background screening as part of the ordinary recruitment process. If criminal offence information or background screening is required for a particular role, this will be handled separately and only where permitted by applicable law.

6. How we collect your personal data

We may collect your personal data from the following sources:

Directly from you, when you submit an application, create an account, provide your CV or cover letter, answer application questions, attend interviews, complete assessments, provide availability or communicate with us.
Through our careers page, where you apply for roles listed by BW ESS.
From recruitment platforms or job boards, where you apply through or are directed from third-party recruitment channels, such as LinkedIn or other job posting platforms.
From recruitment agencies, where an agency submits your details to us in connection with a role.
From referrals, where a BW ESS employee or other contact refers you for a role.
From references, where we contact referees as part of the recruitment process.
From BW ESS employees involved in recruitment, such as members of the People team, hiring managers, interviewers and other hiring team members.

If someone else provides your personal data to us, we expect them to have an appropriate basis for doing so. If you provide personal data about another person, such as a referee, you should ensure that you are permitted to provide that information to us.

7. If you do not provide personal data

You are not required to provide personal data to BW ESS. However, if you do not provide information that is necessary for us to assess your application, communicate with you, verify your eligibility to work, support a visa, work permit or immigration process, comply with legal or regulatory obligations or take steps before entering into an employment contract or engagement, we may not be able to progress your application or offer you a role.

8. Recruitment analytics and reporting

As set out in Section 4 above, BW ESS may use the recruitment platform to generate analytics and reports about recruitment activity. Where possible, reports will be generated using aggregated or anonymised data. Diversity reporting will be handled at an anonymised, aggregated or restricted-access level and will not be used by hiring managers to make recruitment decisions about individual candidates.

Greenhouse may also generate performance and usage data from the operation and use of the Greenhouse services, provided that such data does not include personal data and is not attributed to or otherwise linked to a specific customer.

9. Automated decision-making, profiling and AI

BW ESS does not use the Greenhouse platform to make solely automated recruitment decisions that produce legal or similarly significant effects on candidates.

All hiring decisions are made by people. The platform may be used to record and organise information, including scorecards and interview feedback completed by BW ESS employees, but it is not used by BW ESS to automatically rank, reject or select candidates.

BW ESS does not use the Greenhouse platform's AI functionality in connection with candidate personal data.

10. Sharing your personal data

Purpose for sharing	Personal data shared	Organisations shared with
To facilitate recruitment processes and ensure efficient hiring across the BW ESS group.	Identification and contact details, application information, recruitment assessment information, communication records.	BW ESS Limited departments (including the People team, hiring managers, interviewers, authorised personnel supporting the recruitment process, each on a need-to-know basis) and other BW ESS group companies involved in the recruitment process.
To operate and secure the recruitment platform.	All candidate data submitted via the platform, including application information, interview data and recruitment records	Greenhouse Software, Inc. (platform provider and data processor) and its authorised sub processors.
To source candidates and support applications through recruitment agencies.	Identification and contact details, CV, application status, interview scheduling information.	Recruitment agencies where they are involved in submitting or supporting your application.
To verify candidate information through reference checks.	Identification and contact details, employment history, qualifications.	Referees provided by you.
To receive professional advice in respect of recruitment, legal, compliance or governance matters.	Identification and contact details, application information, diversity data (where relevant), recruitment records.	Professional advisers (e.g. external legal advisers, auditors, insurers if necessary).
Where required by law, for example to verify right to work or comply with legal or regulatory obligations.	Right to work information, recruitment records, and other information required by law.	Government authorities, public authorities, courts, tribunals or law enforcement bodies.
To facilitate recruitment-related integrations (e.g. calendar, email or job board integrations).	Personal data required for the relevant integration to operate such as Calendar / Outlook integration.	Third-party service providers where integrations are enabled by BW ESS.

The Greenhouse platform may support integrations with third-party services, such as calendar, email, job board or other recruitment-related integrations. BW ESS will only enable integrations where they are considered appropriate for recruitment purposes. Where BW ESS enables a third-party integration, personal data may be shared with or accessed by the relevant third-party provider as required for the integration to operate. The relevant third party’s own terms and privacy notice may apply to its separate processing of personal data.

We do not sell your personal data.

Where you apply through a third-party recruitment channel, such as a job board or LinkedIn, that third party’s own privacy terms may also apply to its separate processing of your personal data.

11. International transfers

Your personal data may be processed in countries where BW ESS group personnel involved in recruitment are located, including in the United Kingdom, the European Economic Area (including Germany, Spain and Italy), Switzerland and Australia. Greenhouse may also be used for recruitment in additional countries where BW ESS conducts recruitment activity in the future.

BW ESS has contracted for Customer Data in Greenhouse to be stored on servers located in the European Union for the duration of the agreement. Customer Data is stored at rest in an AWS data centre located in Germany.

However, personal data may be transferred to and processed outside the European Economic Area, including in the United States, for the purposes of providing, supporting and securing the recruitment platform.

Where Australian privacy law applies, this may involve disclosure of personal information to recipients outside Australia, including BW ESS group companies, Greenhouse, Greenhouse’s authorised subprocessors and other service providers involved in recruitment-related services.

Where personal data is transferred internationally, including to jurisdictions without an applicable adequacy decision or recognised transfer framework, BW ESS will take steps designed to ensure that appropriate safeguards are in place (which may be requested from us using the ‘contact us’ details below). These may include:

the EU Standard Contractual Clauses;
the UK International Data Transfer Addendum, where relevant;
Swiss data transfer safeguards, where relevant;
the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework or Swiss-U.S. Data Privacy Framework, where applicable; and
contractual, technical and organisational measures designed to protect personal data.

12. How we protect your personal data

BW ESS applies appropriate technical and organisational measures to protect candidate personal data. These include role-based access controls, internal policies and procedures, staff training, access reviews and incident management procedures.

Greenhouse also applies appropriate technical and organisational measures in connection with the recruitment platform. These measures undergo regular audits and testing.

No system can be guaranteed to be completely secure, but BW ESS has taken appropriate steps designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

13. How long we keep your personal data

BW ESS retains candidate personal data for no longer than necessary for the purposes described in this notice.

Unless a different period is required or permitted by applicable law, BW ESS retains candidate data in the Greenhouse platform for up to 6 months after the relevant application process has ended, including where a candidate has been hired or rejected from all applications.

Personal data relating to BW ESS employees who use the platform, such as members of the People team or hiring managers, will be retained for as long as they require access to the platform to perform recruitment-related functions.

Where you are hired, certain information collected during the recruitment process may become part of your employment record. That information will then be handled in accordance with the applicable employee privacy notice or employment data protection information.

On termination or expiry of the agreement with Greenhouse, personal data will be returned or deleted in accordance with the applicable data processing agreement, unless retention is required by applicable law.

Where personal data is no longer required, it will be deleted, anonymised or otherwise handled in accordance with applicable retention procedures.

14. Your rights

Depending on the law that applies to your personal data, you may have rights to:

request access to personal data or personal information held about you;
request correction of personal data or personal information if you consider it inaccurate, out of date, incomplete, irrelevant or misleading, where applicable;
request deletion of your personal data;
object to certain processing;
request restriction of processing;
request portability of your personal data;
withdraw consent where processing is based on consent;
object to direct marketing, if applicable;
lodge a complaint with a data protection or privacy authority; and
complain to us in relation to how BW ESS is using your personal data or if you consider there has been an infringement of data protection law.

Depending on the functionality available to you, you may also be able to access, update or manage certain personal data through the recruitment platform, including basic contact details.

You may withdraw your application through the platform or by contacting BW ESS. If you withdraw your application, BW ESS may still retain certain personal data where necessary for legal, regulatory, record-keeping, dispute or legitimate business purposes as described in Section 4 above.

These rights are not absolute and may be subject to conditions or exemptions under applicable law.

To exercise your rights, please contact us using the details in this notice.

15. Complaints

If you have concerns about how we handle your personal data, please contact us first so that we can try to resolve the issue.

You may also have the right to lodge a complaint with a data protection or privacy authority in the country where you live, work or where you believe an infringement has occurred. If you are based in the United Kingdom or the European Economic Area, this may include your local data protection supervisory authority. If you are based in Switzerland, this may include the Swiss Federal Data Protection and Information Commissioner. If you are based in Australia, this may include the Office of the Australian Information Commissioner. If Singapore privacy law applies, this may include the Singapore Personal Data Protection Commission.

16. Contact us

If you have any questions about this notice or how BW ESS handles your personal data, or if you wish to exercise your privacy rights, please contact:

BW ESS privacy queries and data subject requests: dpo@bw-ess.com

Data Protection Officer: Justine Fox

If your query relates to the status of your application rather than privacy or data protection, please contact the BW ESS recruitment contact handling your application.

17. Updates to this notice

We may update this notice from time to time to reflect changes in our recruitment processes, technology, legal obligations or data protection practices. Where required, we will provide an updated notice or otherwise inform you of material changes.