Job Applicant Data Privacy Notice
The Starr Group is committed to protecting the privacy and security of your Personal Data.
This privacy notice describes how Starr Group entities collect and use Personal Data about you during the recruitment process with us, in accordance with applicable Data Protection Laws, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and the Data Use and Access Act.
Depending on the role for which you apply, your personal data will be processed by one or more of the following group companies, each acting as an independent data controller:
- Starr Underwriting Agents Limited
- Starr Europe Insurance Limited
- Starr Europe Underwriting Agents Limited
- SWAG
- IQUW Administration Services Limited
Each of the above entities is referred to in this privacy notice as the “Company”, “we, “our”. This means that we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
- Data Protection principles
- We will comply with Data Protection Laws. This says that the Personal Data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
- We will comply with Data Protection Laws. This says that the Personal Data we hold about you must be:
- Information we may collect about you
- Personal Data: We may collect the following and process the following Personal Data about you, whether such information is provided by you or by a third party:
- Your biographical information ► including your name, gender, date of birth, location of previous employment or workplace, previous job history, education details;
- Your contact information ► including your home address, telephone number(s), personal email address, next of kin and emergency contact information;
- Your identification information ► including your national identification number, driving licence, passport information, national insurance/social security number;
- Your recruitment information ► including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process;
- Your performance information ► including management metrics, appraisals, feedback, and disciplinary and grievance information from previous employers; and
- Communications and internet information ► including your correspondence in connection with your application and CCTV footage where you attend our premises.
- Special Categories of Personal Data: Depending on the jurisdiction and role for which you
- apply, we may also collect Special Categories of Personal Data about you strictly where permitted by law and necessary for recruitment purposes, including:
- Health information and medical records, such as fitness to work assessments, disability related adjustments;
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; and
- Criminal convictions data, where required for regulatory obligations, suitability assessments or legally mandated checks.
- Note that in very specific circumstances and in respect of a very limited number of individuals we may also collect Sensitive Personal Data relating to genetic information and biometric data. This is, however, done on a very exceptional basis only and only when permitted by law.
- Personal Data: We may collect the following and process the following Personal Data about you, whether such information is provided by you or by a third party:
- How is your Personal Data collected?
- We typically collect Personal Data about you through the application and recruitment process, either directly from you or sometimes from an employment or recruitment agency, or background screening provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies, referees, training and certification bodies, benefits and pension administrators, public registers, and regulators, as relevant to the purpose.
- What legal basis do we have for using your Personal Data and what are the purposes of the processing?
- We have specified the situations in which we may use your Personal Data. For each use, we note the legal basis for processing your Personal Data. Some of the processing purposes will overlap and there may be several legal basis which justify the processing of your Personal Data.
- To manage recruitment ► including eligibility for work, vetting, and hires.
- We have specified the situations in which we may use your Personal Data. For each use, we note the legal basis for processing your Personal Data. Some of the processing purposes will overlap and there may be several legal basis which justify the processing of your Personal Data.
Legal basis: Contract performance, legitimate interests (to enable us to effectively recruit staff).
- To manage your entitlement to work ► including right to work status.
Legal basis: Contract performance, legitimate interests (to enable us to effectively recruit staff).
- For security purposes ► for providing network and IT support, security and user authentication.
Legal basis: Contract performance, legitimate interests (to enable us to ensure the security of our systems).
- To prevent data losses ► this includes monitoring activities within our business network in order to ensure that we do not lose sensitive data from the company.
Legal basis: Legitimate interests (to enable us to ensure the prevention and detection of data losses).
- To comply with our legal obligations ► we may disclose your Personal Data in connection with proceedings or investigations involving you or other employees, workers and contractors, anywhere in the world to third parties, such as public authorities, law enforcement agencies, regulators and third party litigants (these third parties will process your Personal Data for their own purposes and not on our instructions).
Legal basis: Contract performance, legal obligations, legitimate interests (to enable us to cooperate with law enforcement and regulatory authorities).
- To review our business structure ► We may use your Personal Data for business management and planning purposes, including accounting, internal audits, and related activities that support the effective operation of our business.
Legal basis: Contract performance, legal obligations, legitimate interests (to enable us to effectively manage and operate our business).
- To conduct certain checks on you, such as credit checks and anti-fraud checks ► we may access and use your Personal Data to conduct, credit checks and checks to prevent fraud and money laundering. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to law enforcement agencies and/or relevant authorities including credit reference agencies and fraud prevention agencies. We will also record this.
Legal basis: Legal obligation, legitimate interests (to assist with the prevention of crime and fraud).
- To monitor equal opportunities ► managing ethnic, gender and disability and information as part of our equal opportunities monitoring processes.
Legal basis: Legal obligation, legitimate interests.
Data Protection Officer
Location: Starr Companies, 30 Fenchurch Avenue, London, EC3M 5AD, United Kingdom
Email: ukgdpr@starrcompanies.com
- Changes to this privacy notice
- We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.
If you have any questions about this privacy notice, please contact the Data Protection Officer.
Last updated on 19/05/2026.