Last updated: August 2026
This Candidate Privacy Policy (“Policy”) explains how we collect, use, store and protect your personal information when you visit our careers website; apply for a role with Virgin Active or KAUAI; are referred for a role; are introduced to us by a recruitment agency or other recruitment partner; attend an interview, assessment or recruitment event; or otherwise contact us about career opportunities.
For the purposes of this Policy, “Virgin Active”, “KAUAI”, “we”, “our” and “us” refer to the relevant organisation responsible for the recruitment process and the processing of your Personal Data.
Virgin Active Limited is registered in England and Wales (company number 03448441 and VAT GB 777976151), with its registered office at 26 Little Trinity Lane, Mansion House, London, EC4V 2AR.
KAUAI Juice Limited is registered in England and Wales (company number 14743903 and VAT GB 437159579), with its registered office at 26 Little Trinity Lane, Mansion House, London, EC4V 2AR.
The relevant organisation acts as Controller of the Personal Data processed for its recruitment activities. This means that it determines why and how your Personal Data is used. Our Data Protection contact details are set out below.
This Policy is intended to help you understand what information we collect about you, where it comes from, why we collect it, how it is used and shared, how long we keep it and the rights you have in relation to it.
If you are aged 16 or 17, you can apply for the roles that are open to you. We aim to explain this Notice in clear language, we ask only for the information we need to assess your application, and we do not ask for information about your family or personal circumstances that is not relevant to the role.
What personal data we collect
The information we collect will depend on how you interact with us and the stage you reach in our recruitment process. Information may be provided directly by you or, where appropriate, obtained from third parties.
- Identification data: Your name and other information used to identify you.
- Contact details: Your email address, telephone number, postal address and other information you provide so that we can contact you.
- Application and employment information: Information contained within your application or CV, including your employment history, education, qualifications, professional memberships, skills, experience, languages and other information relevant to your application.
- Recruitment information: Information collected throughout the recruitment process, including interview and assessment responses, interview notes, scorecards, candidate evaluations, communications relating to your application and information you provide through recruitment forms.
- Right to work and verification information: Information required to verify your identity, right to work in the UK and other information necessary to confirm your eligibility for employment.
- Reference information: Information supplied by referees, previous employers or other individuals you have authorised us to contact in connection with your application.
- Recruitment partner information: Information provided to us by recruitment agencies, headhunters, job boards, team member referrers or other recruitment partners where they have lawfully shared your information with us.
- Publicly available professional information: Where appropriate and permitted by law, we may use relevant professional information that you have made publicly available, for example information available through professional networking platforms such as LinkedIn.
- Pre-employment screening information: For certain roles and where permitted or required by law, we may carry out appropriate pre-employment checks after a conditional offer has been made. These may include background, reference or criminal record checks, such as Disclosure and Barring (DBS) checks, depending on the requirements and responsibilities of the role. We will only carry out checks that are appropriate and proportionate to the role, an identified role-related risk and at the level for which the check is legally available and necessary.
- Special category Personal Data: In some circumstances, we may process information relating to matters such as your health, disability, racial or ethnic origin, religion or belief, sexual orientation or other information treated as special category data under data protection law. For example, you may choose to provide information about a disability or health condition so that we can make reasonable adjustments during the recruitment process. We may process health or disability information that is necessary to make reasonable adjustments or, after a conditional offer, to assess a role-specific fitness requirement lawfully. We may also collect voluntary equality-monitoring information, such as racial or ethnic origin, religion or belief, disability or sexual orientation. Where we process this information, we will only do so where there is an appropriate legal basis and condition for processing it.
Health and disability questions before an offer are limited to the circumstances permitted by section 60 of the Equality Act 2010, including arranging reasonable adjustments for the assessment process, monitoring diversity, positive action and establishing whether you can carry out a function intrinsic to the role.
Equality-monitoring information and information requested solely to arrange reasonable adjustments are voluntary. Choosing not to provide equality-monitoring information will not affect your application.
Other information you choose to provide: This includes any additional information you voluntarily provide when contacting us, applying for a role or participating in our recruitment process.
Information we collect when you use our Careers Site
When you visit our Careers Site, we may collect technical information about the device and browser you use. This may include your IP address, date and time of access, browser or device type, the website you arrived from, pages you view and actions you take on the site. This information may be collected through Cookies and similar technologies. You can find more information about the Cookies used on our Careers Site in our Cookie Policy and through the site’s Cookie settings.
How we receive your information
- directly from you when you apply or contact us
- through our Careers Site and applicant tracking system
- from a Virgin Active or KAUAI team member who refers you for a vacancy
- from recruitment agencies, headhunters or other recruitment partners
- from job boards or professional networking platforms
- from referees or previous employers
- from providers carrying out authorised pre-employment checks
- from publicly available professional sources where permitted by law
Where someone else provides us with your information, we expect them to have an appropriate lawful basis for doing so.
How we use your personal data
- provide and administer our careers website and recruitment systems
- receive, process and manage applications for employment
- assess your suitability for a role
- shortlist candidates against relevant requirements for a vacancy
- communicate with you about your application and the recruitment process
- arrange and conduct interviews, assessments and other recruitment activities
- record interview feedback and recruitment decisions
- verify information provided during the recruitment process
- carry out appropriate right to work, reference and pre-employment checks
- make reasonable adjustments during the recruitment process
- carry out voluntary equity monitoring
- prepare and manage offers of employment
- respond to recruitment enquiries
- consider you for other suitable vacancies where appropriate and permitted by law
- manage candidate referrals
- improve our careers website, recruitment processes and candidate experience
- produce recruitment reporting and analytics
- maintain the security and integrity of our websites, recruitment systems and processes
- prevent fraud, unlawful activity or misuse of our systems
- comply with our legal and regulatory obligations
Our lawful bases for using your information
We will only process your Personal Data where we have a lawful basis to do so.
We have a legitimate interest: This is our principal basis for receiving and reviewing applications, assessing and shortlisting candidates, conducting interviews and assessments, sourcing and contacting potential candidates, managing referrals, improving our recruitment process, protecting our systems, maintaining proportionate recruitment records and establishing, exercising or defending legal claims. We assess necessity and balance our interests against your rights, freedoms and reasonable expectations, and document that assessment where appropriate.
It is necessary to take steps at your request before entering into a contract: We rely on this basis only after you have accepted a conditional or unconditional offer, where the processing is necessary to take specific steps to enter into the employment contract, such as finalising the offer or verifying a qualification required for the role.
We need to comply with a legal obligation: For example, where we are required to verify your right to work or meet other employment or regulatory requirements.
You have provided consent: Where consent is the appropriate legal basis, you may withdraw your consent at any time.
Where we process special category or criminal offence data, we will only do so where the additional conditions required by data protection legislation are met.
Automated decision-making and recruitment technology
We use recruitment technology to help administer applications and may use rule-based or other tools to organise, search, filter or prioritise candidate information against stated, role-relevant criteria such as location, experience, skills or qualifications. We apply data-minimisation, accuracy, fairness and bias-testing controls appropriate to the tool and use case.
Recruitment technology may support our recruitment teams and Hiring Managers, but it does not make solely automated decisions that have legal or similarly significant effects on candidates. A suitably authorised human reviewer considers the relevant information, can depart from a tool’s output and makes the recruitment decision. Where we record or automatically transcribe an interview or assessment, or use an AI notetaking, summarising or scoring tool, we will tell you before it is used, explain why we are using it and how long the recording or transcript is kept, and offer a reasonable alternative where practicable. We do not permit our recruitment technology providers to use candidate Personal Data to develop or train their own models unless we have identified a lawful basis and told you.
Recruitment communications and other opportunities
If you apply for a role with us, we will use the contact details you provide to communicate with you about your application and the recruitment process.
Where appropriate and permitted by law, we may also contact you about other suitable career opportunities with Virgin Active or KAUAI. We rely on legitimate interests for proportionate talent-pool activity and provide a clear way to opt out of future-opportunity messages. You can opt out at any time without affecting a current application.
Who we share your data with
Your Personal Data will only be shared where necessary and appropriate for the recruitment purposes described in this Policy.
- Virgin Active and KAUAI team members involved in recruitment
- Hiring Managers and relevant interviewers
- members of our Talent Acquisition and People Team
- authorised system administrators
- companies within our group where appropriate
- recruitment agencies and other recruitment partners
- providers of our applicant tracking, recruitment and interview systems
- providers supporting assessments, background checks, references or right to work verification
- IT, hosting and cloud service providers
- professional advisers where necessary
- regulators, law enforcement bodies, courts or other authorities where disclosure is required or permitted by law
Access to candidate information is provided according to an individual’s role and recruitment responsibilities. Service Providers acting as our processors must follow our documented instructions, confidentiality and data-protection requirements We do not sell your Personal Data.
How we keep your data secure
We use proportionate technical and organisational measures designed to protect candidate information against unauthorised access, alteration, disclosure, loss or destruction. These include role-based access controls, confidentiality obligations, security requirements for Service Providers and procedures for identifying and responding to personal-data breaches.
Where your data is processed
Your Personal Data may be stored, accessed, used or processed outside the UK, including in countries where our recruitment technology providers, service providers or their servers and cloud infrastructure are located.
Where Personal Data is transferred outside the UK, we will ensure that appropriate safeguards are used where required by UK data protection law. These may include an adequacy decision, appropriate contractual protections or other legally recognised transfer mechanisms.
You can contact us if you would like further information about the safeguards we use for international transfers.
How long we keep your data
Candidate data retention period: 365 days
We will retain candidate Personal Data for three hundred and sixty-five days following the end of the relevant recruitment process, unless a different retention period is required by law or is necessary for a specific type of information.
Candidate information may be retained after a recruitment process has ended where this is necessary to manage and evidence our recruitment decisions; comply with legal requirements; establish, exercise or defend legal claims; or consider you for future suitable vacancies where appropriate.
If we retain your details to consider you for future opportunities, we ordinarily do so for up to 12 months from our last meaningful contact with you, tell you that we are doing so and give you an easy way to object. We review talent-pool information and delete it when it is no longer accurate, relevant or needed. We do not retain a copy or representation of a DBS certificate after the relevant decision, although we may retain the minimum check details and outcome permitted by the DBS Code of Practice. If you are appointed, evidence of a right-to-work check is retained securely for the duration of employment and for two years afterwards, in accordance with Home Office guidance, and is then securely destroyed. When the applicable retention period expires, Personal Data will be securely deleted or anonymised unless we have a lawful reason to retain it for longer.
Your data protection rights
- Access your Personal Data and receive information about how we process it
- Correct Personal Data that is inaccurate or incomplete
- Delete your Personal Data in certain circumstances
- Restrict the processing of your Personal Data in certain circumstances
- Object to certain processing, including processing based on our legitimate interests
- Data portability – in certain circumstances, receive Personal Data you have provided to us in a structured, commonly used and machine-readable format
- Withdraw consent where we rely on your consent to process your Personal Data
- You may object at any time to direct marketing, including future-opportunity messages, and we will stop that marketing.
- If we ever use solely automated significant decision-making, you will also have the right to obtain human intervention, express your point of view and challenge the decision.
These rights are subject to certain legal conditions and exemptions and may not apply in every circumstance.
How to exercise your rights
You can exercise your data protection rights or ask questions about how we process your Personal Data by contacting:
Email: personaldata@virginactive.co.uk
Post:
Virgin Active Limited
26 Little Trinity Lane
Mansion House
London
EC4V 2AR
We may need to verify your identity before acting on a request. We will respond without undue delay and normally within one month, subject to lawful extensions and exemptions.
Complaints
If you are unhappy with how we have handled your Personal Data or with our response to a data protection request, you can contact us at: personaldata@virginactive.co.uk
We will acknowledge receipt of a data-protection complaint within 30 days, investigate and respond without undue delay, keep you appropriately informed and tell you the outcome without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data-protection regulator, at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or through ico.org.uk/make-a-complaint.
Cookies and tracking technologies
Our Careers Site uses Cookies and other tracking technologies. Some Cookies are necessary for the Careers Site to operate. Others may be used to understand how visitors use the site, improve the candidate experience or support other website functionality.
You can manage your Cookie preferences through the Cookie settings available on the Careers Site. For further information, please see our Cookie Policy.
What this Policy does not cover
This Policy relates specifically to the Personal Data we process for recruitment and careers purposes.
If you become employed by Virgin Active or KAUAI, the processing of your Personal Data as a team member will be governed by the relevant team member privacy information.
This Policy does not govern the independent processing activities of third-party websites, job boards, recruitment agencies or professional networking platforms that act as separate Controllers. Their own privacy policies will explain how they process your information.
Changes to this Policy
We may update this Policy from time to time to reflect changes to our recruitment processes, Careers Site, recruitment technology, use of Personal Data or applicable data protection legislation.
The latest version will be published on our Careers Site together with the date it was last updated.
Definitions
Controller: means the person or organisation that determines why and how Personal Data is processed.
Personal Data: means information relating to an identified or identifiable individual, directly or indirectly.
Processing: means any operation performed on Personal Data, including collecting, recording, organising, storing, accessing, using, sharing, amending or deleting it.
Special Category Personal Data: means certain particularly sensitive Personal Data given additional protection under data protection law, including information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric information used for identification, health, sex life or sexual orientation.
Careers Site: means the careers website and associated digital recruitment services through which Virgin Active and KAUAI provide employment opportunities and recruitment information.
Service Providers: means third-party organisations engaged to process Personal Data on our behalf and in accordance with our instructions.
Criminal-offence data: means Personal Data relating to criminal convictions and offences, allegations, investigations, proceedings or related security measures, including information confirming the absence of convictions.
Profiling: means automated processing used to evaluate personal aspects relating to you, such as analysing or predicting your suitability, performance, interests, reliability or behaviour.