Riverwell Ltd – Data Protection Policy

Effective Date: 16/07/2025

Data Protection Officer: Sean Flanagan

​

1. Introduction

Riverwell Ltd ("I", “we”, “our”, “us”) is committed to protecting the privacy and personal data of all individuals who interact with our services. This policy sets out how we collect, use, store, share, and protect your personal information, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We operate as a recruitment service provider for both candidates and employers and act as a Data Controller for the personal data we process through our website and related services.

​

2. Contact Details

Company Name: Riverwell Ltd

Company Address: 43 All Hallows Rd, Caversham, Reading, RG4 5LP

Email: info@riverwelltr.com

Data Protection Officer (DPO): Sean Flanagan

​

3. What Personal Data We Collect

We collect personal data from both job seekers and employers, including:

For Candidates

• Full name

• Contact information (email, phone number)

• CV/resume and cover letters

• Employment history and qualifications

• Job preferences (e.g., role, location, salary)

• Right-to-work information (if applicable)

• Notes from interviews or calls

​

For Employers and Clients

• Contact name, job title, and company name

• Business contact details

• Job vacancy details and hiring preferences

​

Automatically Collected Data

• IP address, device/browser info

• Website usage (pages visited, time spent)

• Cookies and tracking data (see Section 7)

​

4. How We Use Personal Data

• Provide recruitment services and match candidates with roles

• Allow candidates to submit CVs and applications

• Communicate with users regarding applications, interviews, and feedback

• Send job alerts or updates (where consent is given)

• Share candidate details with prospective employers (with consent)

• Comply with legal obligations

• Improve our website and user experience

​

5. Lawful Bases for Processing

• Consent – for marketing emails, job alerts, or CV submissions

• Contract – where data processing is necessary to fulfil a service (e.g., connecting candidates with job opportunities)

• Legitimate Interests – for recruitment activity, website performance monitoring, and service improvement

• Legal Obligation – to comply with employment or tax regulations

​

6. Data Sharing

• Clients/employers: to put you forward for relevant roles (only with your consent)

• Job boards or applicant tracking systems: if integrated into our services

• Service providers, such as cloud hosting, analytics platforms, or CRM systems

• Regulators or legal authorities: if legally required

• We never sell your personal data to third parties.

​

7. Cookies and Analytics

• Monitor website performance

• Understand user behaviour

• Improve site functionality

• You will be notified via a cookie banner and can manage preferences or opt out through your browser.

• For more details, see our Cookie Policy (if applicable).

​

8. International Transfers

• Adequacy decisions

• Standard Contractual Clauses (SCCs)

• Binding Corporate Rules (BCRs), where applicable

​

9. Data Retention

• Job seeker data: up to 2 years after last interaction, unless consent is renewed

• Employer data: as long as you are a client or for legal compliance

• CVs or applications may be retained longer if you opt into a talent pool

• You may request deletion at any time (see Section 11).

​

10. Data Security

• Encrypted connections (HTTPS/SSL)

• Secure data storage

• Access controls and authentication

• Staff training on data handling

​

11. Your Rights

• Access – request a copy of your personal data

• Rectification – correct inaccurate or incomplete data

• Erasure – request deletion of your data (“right to be forgotten”)

• Restriction – ask us to limit processing

• Portability – receive your data in a portable format

• Objection – object to processing based on legitimate interests

• Withdraw consent – at any time for activities based on consent

• To exercise your rights, email us at [Insert your email].

​

12. Complaints

• If you have concerns about how we use your data, please contact our DPO first.

• If unresolved, you may complain to:
  Information Commissioner’s Office (ICO)
  Website: https://ico.org.uk
  Phone: 0303 123 1113

​

13. Changes to This Policy

• We may update this policy occasionally. The most recent version will always be available on our website.

 

14. Contact Us

• If you have any questions about this policy or your data, contact:
  Riverwell Ltd
  Email: Info@riverwelltr.com
  Data Protection Officer:  Sean Flanagan