Recruitment Data Policy

Massive Interactive Media Limited



Introduction and scope of privacy notice

This Recruitment Privacy Notice explains the type of information Massive Interactive Media Limited or its affiliated entities (collectively, “we” or “Massive”) may process, why we are processing it, and how that processing may affect you as a prospective hire of Massive.

What do we mean by “personal data” and “processing”?

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system.  It includes not only facts about you, but also intentions surrounding our potential hiring of and opinions about you.

“Processing” means doing anything with the data – including collecting it, holding it, disclosing it or deleting it.

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to additional protections under the law, as such data is considered by EU privacy law to be “sensitive personal data”.

Your personal data

We process your personal data for the purposes of fulfilling our recruitment and hiring practices.  Some of the personal data that we process about you comes from you directly.  For example, you when you provide us with your contact details.  Other personal data about you is generated from references and third party companies such as recruitment agencies.  Your personal data will be seen internally by managers, administrators and HR.

How long do we keep your personal data?

If you are successful in your application your data will be kept on your personnel file.  If you are unsuccessful, you data will normally be destroyed within a reasonable period after you have been informed that you were unsuccessful, likely no longer than twelve months.  Irrelevant data such as CCTV images may be deleted after a short period.

Transfers of personal data outside the EEA

We are headquartered in the United Kingdom with offices in Sydney, New York City and Prague.  Therefore, we may transfer your personal data outside the EEA to members of our group and their authorized processors.  Where necessary, these transfers are covered by an intra-group transfer agreement ensuring appropriate and suitable safeguards with our group members.  Please contact HR or the Massive Legal Department if you wish to learn more about these safeguards.

Contact details

In processing your data Massive or its affiliated entities, may act as a data controller.  If you have questions as to how your data is being processed, please contact Massive at

Legal grounds for processing personal data

What are the grounds for processing?

Under data protection law, there are various grounds on which we can rely when processing your personal data.  In some contexts more than one ground applies.  Two of those grounds can be summarised as Legal Obligation and Legitimate Interests.  We outline what those terms mean below:


Term Ground for processing Explanation
Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Legitimate Interests Processing necessary for our or a third party’s legitimate interests We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.


Processing sensitive personal data

If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one of the grounds for processing sensitive personal data applies, including (for example) that the processing is for equality and diversity purposes to the extent permitted by law.

Further information on the data we process and our purposes

Examples of the data and the grounds on which we process data are in the table below.  The examples in the table cannot, of course, be exhaustive.


Purpose Examples of personal data that may be processed Grounds for processing
Recruitment Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work. If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements. Legal obligation

Legitimate interests

Contacting you or others on your behalf Your address and phone number, emergency contact information and information on your next of kin. Legitimate interests
Security CCTV images Legal obligation

Legitimate interests

Monitoring of diversity and equal opportunities Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age. Legitimate interests


Who gets to see your data?

Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this document.  We may also disclose this to other members of our group.

Access to your personal data and other rights

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and an explanation of why we are processing it.

  • If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
  • As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. You may also have the right to be given your data in a machine readable format for transmitting to another data controller though this right is unlikely to be relevant to you the context of our recruitment processes.
  • We are unlikely to rely on consent as a ground for processing. However, if we do, you may withdraw consent at any time — though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.


If you have complaints relating to our processing of your personal data, you should raise these with HR in the first instance.

You may also raise complaints with the applicable statutory regulator in your jurisdiction.