Table of contents
So Energy Candidate Privacy Notice
2. Who we are
3. The information we collect about you
Identity and contact information
Application and professional information
Recruitment and assessment information
Right-to-work and pre-employment information
Information from professional or public sources
Referee information
Careers site and technical information
4. Special category and criminal offence information
5. Where we obtain your information
6. How and why we use your information
7. Where we rely on legitimate interests
8. Candidates we identify or who are referred to us
9. Interviews, assessments and recruitment technology
10. Our talent network and future opportunities
11. Who we share your information with
Recruitment and applicant management services
Assessment and interview services
Recruitment agencies and sourcing services
Background screening and verification services
Technology, cloud and cybersecurity services
Professional and specialist advisers
12. Cookies and careers site analytics
13. International transfers
14. How long we keep your information
15. If you do not provide information
16. How we keep your information secure
17. Using your information for a new purpose
18. Your data protection rights
Access your information
Correct inaccurate information
Ask us to delete information
Restrict our use of your information
Object to processing
Data portability
Withdraw consent
Rights relating to automated decisions
19. Complaints about how we use your information
20. Changes to this Privacy Notice
So Energy Candidate Privacy Notice
Last updated: November 2026
1. About this Privacy Notice
At So Energy, we take the protection of your personal information seriously.
This Privacy Notice explains how we collect, use, share, store and protect your personal information when you visit our careers site, apply for a role with us, connect with us about future opportunities, are identified as a potential candidate, are referred to us, or provide information as a referee.
It also explains where we obtain information about you from other sources and the rights you have under UK data protection law.
This notice applies to:
visitors to our careers site;
people who apply for roles with So Energy;
people who register or connect with us about current or future opportunities;
people we identify as potential candidates from professional or publicly available sources;
people referred to us as potential candidates; and
people identified as referees for candidates.
If you join So Energy, information relating to your employment will be processed in accordance with our Employee Privacy Notice.
2. Who we are
So Energy Trading Limited is the controller of your personal information where we decide how and why it is used.
So Energy Trading Limited is registered in England and Wales under company number 09263295.
Registered address: Studio 2, Power Road Studios 114 Power Road Chiswick W4 5PY
You can contact our Data Protection Officer at:
Email: data.protection@so.energy
If you want to exercise your data protection rights, you can contact:
Email: DSR@so.energy
3. The information we collect about you
The personal information we collect depends on how you interact with So Energy and the stage of the recruitment process.
Depending on your circumstances, this may include:
Identity and contact information
Application and professional information
This may include:
CV and cover letter;
employment history;
current and previous roles;
education and qualifications;
professional memberships;
skills and experience;
work samples or portfolios;
salary expectations;
notice period;
information about the type of role you are looking for;
information you provide in your application or candidate profile.
Recruitment and assessment information
This may include:
interview notes;
recruiter and hiring-manager notes;
assessment and test results;
answers to recruitment questions;
suitability assessments;
interview recordings where applicable;
recruitment correspondence;
feedback;
information about the outcome of your application.
Right-to-work and pre-employment information
Where relevant to the stage of recruitment, this may include:
proof of identity;
right-to-work information;
immigration or visa information;
references;
background screening information;
criminal offence information where a check is appropriate and legally permitted;
information needed to complete pre-employment checks.
Information from professional or public sources
Where appropriate, we may process information contained in professional profiles or other legitimate public sources, such as:
Referee information
If you act as a referee, we may process:
Careers site and technical information
When you use our careers site, we may collect:
IP address;
browser and device information;
operating system;
pages viewed;
interactions with the site;
traffic source;
cookie identifiers;
other technical information about your use of the site.
More information about cookies and similar technologies is available through our careers site's cookie information.
4. Special category and criminal offence information
Some information receives additional protection under UK data protection law.
Depending on the circumstances, recruitment may involve information about:
For example, we may process health or disability information to make reasonable adjustments during recruitment.
We may also collect diversity information to understand and improve equality of opportunity within our recruitment processes. Where such information is requested for monitoring purposes, we will explain whether providing it is voluntary and will use aggregated or anonymised information where appropriate.
We only process special category information where we have an appropriate lawful basis and an additional condition permitting us to do so.
We may process criminal offence information where this is appropriate for a particular role and permitted by law, including where a criminal-record or background check is justified.
We only process criminal offence information where we have an appropriate lawful basis and a condition under the Data Protection Act 2018 permitting the processing.
5. Where we obtain your information
We obtain much of your personal information directly from you.
For example, you may provide information when you:
apply for a role;
create or update a candidate profile;
connect with us about future vacancies;
communicate with our recruitment team;
attend an interview or assessment;
complete recruitment documentation;
participate in a survey;
provide information during pre-employment checks.
We may also obtain information from:
recruitment agencies and recruitment services;
employees or other people who refer you;
referees;
previous employers;
professional networking platforms;
publicly available professional sources;
background-screening providers;
right-to-work and identity-verification services;
criminal-record checking services where applicable;
assessment providers;
professional or regulatory bodies; and
other organisations involved in our recruitment process where obtaining information is necessary and lawful.
If you provide information about another person, such as a referee, you should ensure they are aware that you have provided their details to us.
6. How and why we use your information
We only use personal information where we have a lawful reason to do so.
PurposeExamplesMain lawful basisManaging applicationsReceiving and reviewing applications, communicating with candidates and arranging interviewsSteps before entering into a contract and legitimate interestsAssessing candidatesInterviews, assessments, shortlisting and evaluating suitabilitySteps before entering into a contract and legitimate interestsFinding potential candidatesReviewing professional profiles, sourcing and approaching potential candidatesLegitimate interestsMaintaining our talent networkKeeping in touch about relevant future opportunitiesLegitimate interests and, where applicable, consentReferralsConsidering people referred to us for rolesLegitimate interestsReferences and pre-employment checksObtaining references and carrying out proportionate checksSteps before entering into a contract, legal obligation and legitimate interestsRight-to-work checksConfirming eligibility to work in the UKLegal obligationReasonable adjustmentsSupporting candidates with disabilities or health needs during recruitmentLegal obligation, with an appropriate special category conditionEquality and diversityMonitoring and improving equality of opportunityLegitimate interests and/or legal obligations, with an appropriate special category conditionCareers site operationProviding, maintaining and securing our careers siteLegitimate interestsCareers site analyticsUnderstanding how our careers site is used and improving itLegitimate interests and/or consent where requiredDefending legal rightsResponding to complaints, disputes or legal claimsLegitimate interests and legal claims conditions where applicableCompliance and securityPreventing fraud, protecting our systems and meeting legal obligationsLegitimate interests and legal obligation
7. Where we rely on legitimate interests
Where we rely on legitimate interests, these may include:
attracting and recruiting people with the skills and experience So Energy needs;
identifying suitable people for current and future opportunities;
operating an effective and fair recruitment process;
maintaining an appropriate talent pool;
communicating with potential candidates;
improving our careers site and recruitment processes;
protecting our systems, information and business;
preventing and investigating fraud or misuse;
maintaining appropriate recruitment records; and
establishing, exercising or defending legal claims.
Before relying on legitimate interests, we consider whether the processing is necessary and balance our interests against your rights, interests and reasonable expectations.
8. Candidates we identify or who are referred to us
You do not always need to have applied directly to So Energy for us to hold limited information about you.
We may identify potential candidates through legitimate professional or publicly available sources, or receive your details from:
We may use this information to assess whether your professional experience appears relevant to a current or potential opportunity and to contact you about that opportunity.
Where we obtain information about you from another source, we will provide privacy information as required by data protection law.
9. Interviews, assessments and recruitment technology
We may use technology to support parts of our recruitment process, including:
managing applications;
scheduling interviews;
communicating with candidates;
carrying out or recording assessments;
analysing recruitment information;
helping recruiters and hiring managers review applications.
Where an interview is recorded, we will tell you before the recording takes place and explain the purpose of the recording.
We may use automated or AI-assisted technologies to support recruitment activities where appropriate. The use of technology to assist a recruiter does not necessarily mean that a decision is made solely by automated means.
Where So Energy makes a decision about you solely through automated processing and that decision produces a legal or similarly significant effect, we will provide the information and safeguards required by data protection law.
Where appropriate, we will provide additional information about particular recruitment technology at the point it is used.
10. Our talent network and future opportunities
If you connect with us or we consider that your professional profile may be relevant to future opportunities, we may retain appropriate candidate information so that we can contact you about suitable vacancies.
This may include:
You can ask us to stop contacting you about future opportunities or request deletion of your candidate profile, subject to information we need to retain for another lawful purpose.
11. Who we share your information with
We share candidate personal information where necessary to operate our recruitment process, assess applicants, make appointments, comply with our obligations or protect our legitimate interests.
Some organisations process information on our behalf and according to our instructions. Others may receive information as independent controllers and are responsible for their own use of it.
The types of services we may use include:
Recruitment and applicant management services
These help us advertise vacancies, manage candidate profiles and applications, communicate with candidates and administer recruitment.
Assessment and interview services
These help us conduct interviews, assessments, testing and other recruitment activities.
Recruitment agencies and sourcing services
These help us identify and recruit potential candidates.
Background screening and verification services
These help us verify identity, employment history, qualifications, right-to-work information or other relevant pre-employment information where appropriate.
Technology, cloud and cybersecurity services
These help us operate and secure recruitment systems, store information, provide communications technology and protect personal information.
Professional and specialist advisers
These include legal advisers, auditors and other professional services where relevant to recruitment, disputes or legal obligations.
We may also share information where appropriate with:
referees;
previous employers;
professional or regulatory bodies;
courts and tribunals;
law enforcement bodies;
public authorities;
immigration and right-to-work authorities;
criminal-record checking bodies where applicable;
organisations involved in corporate transactions or restructuring; and
other organisations where disclosure is required or permitted by law.
Where an organisation processes information on our behalf, we require appropriate contractual, confidentiality and security protections.
12. Cookies and careers site analytics
Our careers site uses cookies and similar technologies.
Some technologies are necessary for the site to operate. Others may help us:
understand how the careers site is used;
remember preferences;
measure site performance;
understand recruitment traffic and engagement; and
improve the candidate experience.
Where consent is required, optional cookies or similar technologies will only be used after you have agreed to them.
Further information, including how to manage your preferences, is available in our careers site's Cookie Policy.
13. International transfers
Some organisations that provide recruitment, technology or other services to us may process or access personal information from outside the UK.
Where personal information is transferred outside the UK, we put appropriate safeguards in place as required under UK data protection law.
Depending on the circumstances, these safeguards may include:
UK adequacy regulations;
the UK International Data Transfer Agreement;
the UK Addendum to the EU Standard Contractual Clauses; or
another legally recognised transfer mechanism.
Where required, we assess the risks associated with an international transfer and implement additional contractual, technical or organisational safeguards.
You can contact our Data Protection Officer for more information about safeguards applicable to a particular transfer.
14. How long we keep your information
We keep personal information only for as long as it is needed for the purpose for which it was collected and to meet our legal, recruitment and operational requirements.
Different information may therefore be kept for different periods.
A general guide is:
Type of informationHow long we generally keep itUnsuccessful candidate application and recruitment recordsGenerally for up to 12 months after the recruitment process endsCandidate talent-pool informationGenerally for up to 12 months from your last meaningful interaction with us, unless refreshed or a longer period is justifiedReferee informationGenerally in line with the relevant candidate's recruitment recordInterview recordingsFor a limited period necessary for the recruitment purpose, and deleted when no longer requiredCareers site security informationFor a limited period appropriate to the security purposeCookie and analytics informationIn accordance with the periods set out in our careers site cookie informationData protection rights request recordsGenerally for up to 3 years after the request is closedComplaints, disputes and legal claimsFor as long as reasonably necessary to manage the matter and meet our legal obligations
If you become an employee, information needed for your employment will form part of your employee record and will be retained in accordance with our Employee Privacy Notice.
Retention may be shorter or longer where:
a legal or regulatory requirement applies;
information is relevant to a complaint or legal claim;
there is an investigation or legal hold; or
there is another lawful reason to retain it.
When personal information is no longer required, we securely delete or anonymise it.
15. If you do not provide information
Some information is necessary for us to assess your application or meet a legal requirement.
If you do not provide required information, we may not be able to:
process your application;
assess your suitability for a role;
contact you about your application;
carry out required pre-employment checks;
verify your right to work; or
make or complete an offer of employment.
Where providing information is voluntary, we will make this clear where appropriate.
16. How we keep your information secure
We use technical and organisational measures designed to protect candidate personal information against accidental or unlawful loss, misuse, alteration, unauthorised access or disclosure.
These include appropriate controls relating to:
Access to recruitment information is restricted to people who need it for their work.
We regularly review our security measures to ensure they remain appropriate to the nature of the information we process and the risks associated with its use.
17. Using your information for a new purpose
We will normally only use your personal information for the purposes for which it was collected.
If we need to use it for another purpose, we will assess whether the new purpose is compatible with the original purpose and whether we have an appropriate lawful basis.
Where required, we will provide additional privacy information before using your information for a new purpose.
We may process your information without consent where another lawful basis permits or requires us to do so.
18. Your data protection rights
Depending on the circumstances, you have rights over your personal information.
These include the right to:
Access your information
You can ask for a copy of the personal information we hold about you.
Correct inaccurate information
You can ask us to correct inaccurate information or complete information that is incomplete.
Ask us to delete information
In certain circumstances, you can ask us to erase your personal information.
This right does not apply where we have a legal or other valid reason to retain it.
Restrict our use of your information
You can ask us to restrict processing in certain circumstances.
Object to processing
You can object to processing based on legitimate interests in certain circumstances.
Data portability
In certain circumstances, you can ask us to provide information you gave us in a structured, commonly used and machine-readable format or transfer it to another organisation.
Withdraw consent
Where we rely on consent, you can withdraw it at any time.
Withdrawal does not affect processing that was lawful before consent was withdrawn.
Rights relating to automated decisions
You may have rights where a decision that significantly affects you is made solely through automated processing.
To exercise your rights, you can use the privacy controls available through our careers site where available, or contact:
DSR@so.energy
We will normally respond within one month of receiving a valid request. Where the law permits an extension, we will tell you.
19. Complaints about how we use your information
If you have concerns about the way we use your personal information, you can contact our Data Protection Officer:
Data Protection Officer Email: data.protection@so.energy
We will investigate data protection concerns and take appropriate action where necessary.
You also have the right to complain to the Information Commissioner's Office, the UK's data protection regulator.
20. Changes to this Privacy Notice
We keep this Candidate Privacy Notice under regular review.
We may update it when our recruitment practices, careers technology, legal obligations or use of personal information changes.
Where we make a significant change to how we use candidate personal information, we will take appropriate steps to bring the change to your attention before the new processing begins where required.
