Privacy Policy

Who are we?

Change Digital, a trading division of HRL 2 LIMITED

Company number: SC414412

Head Office:

2 Manor Place, Edinburgh, EH3 7DD

Tel: 0131 225 7744

Our Privacy Promise

We promise that we’ll tell you how we use your data and we’ll only use it in providing you with our recruitment services. We will make sure we collect and store your data securely.

Safety is our number one priority

We have to collect and keep data about you, including your name, email address and CV for the purpose of a job search. We also have to share your data with our trusted partners, like our clients who are your potential employer or who require your services, those third parties who maintain our database, our server and those who keep them secure. This is required in order for us to provide the service you have requested from us and also allows us to fulfil our obligations to the organisations mentioned and identify you as a suitable candidate for them. We promise to collect, process, store and share your data safely and securely. We’ll also make sure that the other businesses we work with adhere to the same standards.

Using your data for marketing

If you choose to sign up for email communications we can send you relevant job alerts as soon as they come in. We can also alert you to any up and coming events we are coordinating or attending. You can control these emails by emailing

We use data to help you stand out to a potential client

We use your CV with the details of your qualifications and experience to show clients what a great candidate you are. We can also use your covering letter and collected references from your consented referee’s. Your personal data will be transmitted to a potential client only with your full knowledge. When you have an offer of employment or a contract for services, we may then share more of the personal documents that you have provided us with to your new employer or the client requesting your services.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

You’re in control of your data

If you would like to stop receiving marketing from us, you can email us at with the header “Unsubscribe”. If the information we hold on you is wrong you can email us at and let us know what needs updating and we will correct it for you.

If you would like to be removed completely from our database and all personal data removed, you can email us at with the subject “Remove”.

Please note once removed we will no longer have access to any of your personal data, any previous communications or the fact you have been asked to be removed. If your contact details are in the public domain then we may contact you again. There are occasions where we need to retain your records but we will not contact you if you do not want us to unless there is a legal reason to do so and we will delete your statutory data once it has exceeded the statutory length of time.

Our Privacy Policy in full

Change Digital is committed to protecting your safety and privacy, and takes its responsibilities regarding the security of candidate and client information very seriously. This privacy policy explains what personal data we collect about you, how and why we use it, who we disclose it to, and how we protect your privacy.

1. Who is responsible for your data

Our Privacy Policy applies to the personal data that Change Digital collects and uses. References in this Privacy Policy to “Change Digital”, “we”, “us” or “our” mean Change Digital, a company registered in Scotland with registration number SC414412 and registered office 2 Manor Place, Edinburgh, EH3 7DD.

We control the ways your personal data are collected and the purposes for which your personal data are used by Change Digital and are the “data controller” for the purposes of the UK Data Protection Act 1998, the General Data Protection Regulation and other applicable European data protection legislation. Our current Data Protection Officer is Angela Mulheron.

2. Personal data we collect about you and how we use it

When using the term “personal data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include, for example:

  • Your name
  • Contact details
  • Emergency contact details
  • A copy of your CV

Other information relating to your recruitment needs or application such as your qualifications, salary and benefits or positions you have previously applied for.

We may be required to process additional information for candidates contracted through Change Digital under a contract for services with the contractor’s limited company or Umbrella Company to any of our clients, this may include:

  • Company number
  • Bank details
  • NI number
  • Tax details
  • References
  • Details of criminal convictions
  • Credit check
  • Proof of address
  • VAT registration
  • Applicable insurances
  • Information relating to any previous position held as a Director, Secretary or association to a company
  • Required day rate

Candidates who would be self-employed as a contractor will need to provide some additional information which may include:

UTR number

This is data that you will provide us strictly for the purpose of your job search and the recruitment process. We may hold your CV and data relating to job searches for up to 6 years. This is to ensure that candidates who have requested our recruitment services don’t need to continually re-apply to us. In order for us to provide the best possible service we’d request candidates to update their data with us as and when there is a material change.

We collect some personal data from you, for example when you use our website, use our services or contact us in anyway. We may also receive your personal data from third party providers (for example if you sign up to job sites, online CV directories and social media sites).

For more information, please see Section 7 below.

If you fail to provide certain information when requested, we may not be able to represent you as a recruitment agency (for permanent positions) or as a recruitment business (for contracts positions), or we may be prevented from complying with our legal obligations such as to ensure the health and safety of our workers.

Sensitive personal data

In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences or any investigations. Such information is considered “sensitive personal data” under the UK Data Protection Act 1998, the General Data Protection Regulation and other data protection laws. We only collect this information where you have provided it, it is necessary for the purposes outlined in this Privacy Policy or you have deliberately made it public.

For example, we may collect this information if your new employer has requested it as part of the on boarding process (location dependent), to ensure you are eligible to work in the UK, in order to meet legal obligations, or when it is needed to assess working capacity on health grounds, subject to appropriate confidentiality safeguards.

If you provide any sensitive personal data we will collect and use it in order to provide our recruitment services and in accordance with this Privacy Policy.

3. How and why we use your personal data

We use your personal data for the following purposes:

To communicate with you about our current vacancies and recruitment services – we need certain personal information primarily to allow us to perform our recruitment services with you and to enable us to comply with legal obligations. The situations in which we will process your personal information include:

  • Providing our recruitment services
  • To maintain business relationships with clients and candidates
  • To submit your CV to third parties i.e. prospective clients
  • Checking you are legally entitled to work in the UK
  • Assessing qualifications for a particular job
  • To determine your suitability for a particular job
  • To ensure your own safety and security
  • To comply with our legal obligations, we will retain certain records for a period of up to 7 years for HMRC purposes.

If you are engaged as an employee or contractor through Change Digital we may also need additional information for the following reasons:

  • Administering the contract we have entered into with you
  • Paying you, deducting tax and National Insurance contributions if appropriate
  • Dealing with legal disputes involving you, or other employees, workers and contractors
  • To prevent fraud

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only send you marketing communications if you express a wish to receive such communications. Please note that we do not share your contact details or other personal data gathered for the purposes of recruitment, with other companies for their marketing purposes.

If having elected to receive marketing communications from us and you decide you no longer wish to do so, you can simply tell us by mailing with the header “Unsubscribe”.

You can also choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us.

4. Requesting access to your personal data

You have a right to request access to the personal data that we hold about you. This could include any documents we have collected from you in the recruitment process.

If you would like to request a copy of your personal data, or if you have questions in relation to your personal data, please contact us at with the following information:

  • your full name
  • a description of the data that you are requesting
  • all email addresses (past and present) used

From the date that we receive the request we have – under the relevant legislation – one month to process your request. Whilst we will endeavour to process your request in advance of this deadline, we cannot guarantee that this will be the case. Please note that:

  • The clearer and more specific your request, the easier it will be to respond within the timeframe permitted. Conversely, any requests which are vague may not produce all or indeed any of the information you are looking for.
  • We may in very exceptional circumstances need to charge you for providing information requested to cover our costs but we will notify you of this in advance.

5. Security of your personal data

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. When you provide your personal data through our website or our representatives this information is transmitted across the internet securely using high-grade encryption.

As described in this Privacy Policy, we will in some instances need to disclose your personal data to third parties and other entities within the group, with your consent, for the purpose of our recruitment process. Where Head Resourcing discloses your personal data to a third party, we require that third parties have appropriate technical and organisational measures in place to protect your personal data. Where appropriate we will inform you about the specific third parties with whom this information will be shared before doing so.

We may share your personal information with third parties where required by law including relevant tax authorities e.g. HMRC, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

The information that you provide to us will be held in our systems, which are located on our premises or those of appointed third parties. We may also allow access to your information by other third parties who act for us for the purposes described in this Privacy Policy. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”) – including by staff operating outside the EEA who work for our clients in recruitment services (this includes staff engaged in, among other things, the processing of your application for employment). Where your personal data are transferred outside of the EEA, we require that appropriate safeguards are in place and they comply with this policy.

Change Digital uses third parties for its email delivery service, IT infrastructure maintenance and data hosting facilities and we use Bullhorn as our database. We will retain your personal data for only as long as is necessary in order to fulfil our purposes set out in this Privacy Policy or in order to comply with the law.

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

6. Cookies or other tracking technologies

In order to improve our services, to provide you with more relevant content and to analyse how visitors use our website, we may use technologies, such as cookies. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

Change Digital may set and access Cookies on your computer. Cookies may be placed on your computer when you visit certain parts of the Website. Change Digital use these to identify and track visitors, their usage of the Website, their access preferences and for advertising.

7. Sharing your personal data

Your personal data may be shared with other parties involved in your recruitment process e.g. your new employer, the end client for a contract of services.

It may also be disclosed to a third party who acquires us, and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.

In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.

Third parties may share your data with us for example job boards or online directories. If you do not wish to be informed about our job opportunities or forthcoming events you can be removed from the contact list provided by our supplier by emailing to unsubscribe. Change Digital cannot be responsible for the entry of your data onto these sources but will certainly action any requests not to be contacted by us and will always share with you how we received your information so you have greater control over your personal data.

8. Updates to our Privacy Policy

We may make changes to this Privacy Policy from time to time. We will update the Privacy Policy and we will publish on our website any new version of this Policy.

9. Contact information

Questions, comments, requests and complaints regarding this privacy policy are welcomed and should be addressed to Angela Mulheron, Data Protection Officer,, 0141 566 8648

10. Making a complaint

If you feel that we have been unable to resolve your complaint you can contact the Information Commissioner’s Office via their website or call them on their help line 0303 123 1113.