Version: 2.0   |   Last Updated: 3rd February 2026

Data controller

The Company: Sigma Labs Xyz Ltd (Company number: 13174424)

Registered address: 20-22 Wenlock Road, London, England, N1 7GU

Contact email: compliance@sigmalabs.co.uk

Data protection responsibility

Responsibility for data protection compliance sits with our Finance Director (Contact compliance@sigmalabs.co.uk).

1. Purpose of this notice

As part of any recruitment process, Sigma Labs Xyz Ltd collects and processes personal data relating to job applicants. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

2. What information does the Company collect?

The Company collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number
• details of your qualifications, skills, experience and employment history (including CVs and applications)
• assessment results and interview notes
• information about your entitlement to work in the UK
• whether you have a disability for which the Company needs to make reasonable adjustments during the recruitment process
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief (where collected)
• communication records (for example emails and messages)
• operational records relevant to recruitment decisions (for example re-application eligibility rules and client role flexibility data)

The Company collects this information in a variety of ways. For example, data might be contained in online forms, CVs, obtained from identity documents, or collected through interviews or other forms of assessment (including online tests where used).

The Company may also collect personal data about you from third parties, such as:

• details from professional networking platforms, job boards or recruitment sources you use
• references supplied by former employers (normally after an offer, where used)
• information from online forms and assessment providers (where used)

Data will be stored in a range of different places, including on your application record, in HR systems and on other IT systems (including email and platforms used for recruitment).

Website analytics and cookies (careers/recruitment website users)

Where you visit our website, we may use Google Analytics to understand how visitors move through the recruitment journey, including where applicant traffic drops off and where traffic comes from.

The Company confirms that Google Analytics (non-essential) cookies are only used where you have provided consent via the cookie banner / preference tool and that you can change your preferences at any time via this link.

3. Why does the Company process personal data?

The Company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, the Company needs to process data to ensure that it is complying with legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability and decide whom to offer a job. The Company may also need to process data to respond to and defend against legal claims.

Where the Company relies on legitimate interests as a reason for processing data, it has considered whether those interests are overridden by the rights and freedoms of job applicants and has concluded that they are not.

4. Why does the Company process special categories or criminal convictions data?

The Company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability, or adjustments to a role for a successful candidate. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the Company processes other special categories of data (such as information about ethnic origin, sexual orientation, health or religion or belief), this is for equal opportunities monitoring purposes. This is done as permitted by the Data Protection Act 2018 for reasons of substantial public interest. However, for some data, job applicants are free to decide whether to provide such data and there are no consequences if they choose not to.

Criminal convictions data

As part of employee onboarding, all potential employees for all roles will go through a BPSS check, which includes a Basic Disclosure & Barring Service (DBS) check. We complete these checks for general company security and risk management, and for our work with clients in high risk industries.

The Company will not use your data for any purpose other than the recruitment exercise for which you have applied.

Talent pool

The Company may retain the personal data of candidates who were not successful in their application, but may be worth considering for future opportunities. This allows us to offer these candidates the opportunity to be reconsidered for future recruitment stages or interviews without having to restart the full application process. Participation in this process is optional. If a candidate explicitly chooses not to take up this opportunity, their data will be treated in the same way as any other unsuccessful applicant, in line with our standard retention periods.

5. Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the recruitment team, interviewers, and operations staff where access is limited to what is necessary for their roles.

The Company will not share your data with third parties unless required for the recruitment process and only where appropriate. This may include third-party assessment providers.

Where relevant to the opportunity, we may also share limited applicant information with client organisations for the purpose of assessing suitability for roles or placements. Only the information necessary for this purpose is shared.

If your application is successful and the Company makes you an offer of employment, it may share your data with former employers to obtain references and with providers used for pre-employment checks (where used).

6. International transfers

The Company may store or process personal data using third-party platforms or service providers that are based outside the UK, or that use servers located outside the UK.

Where personal data is transferred outside the UK, the Company ensures that appropriate safeguards are in place to protect personal data in accordance with UK data protection law.

Any access to or sharing of personal data outside the UK is limited to what is necessary for the relevant purpose, and is subject to appropriate contractual and security measures.

7. How does the Company protect data?

The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by employees in the proper performance of their duties.

The Company has appropriate technical and organisational controls in place to ensure this. These include account security measures for online platforms, encryption, secure storage arrangements, permission-based access controls, and data retention and data deletion controls.

Where the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

8. How long does the Company keep data?

If your application is unsuccessful, the Company will hold your data on file for up to two years from the date your application status was last updated. Candidate data is permanently anonymised and deleted on a quarterly cycle (January, April, July, October).

If you join our programme and/or become an employee, personal data gathered during the recruitment process will be transferred to your personnel file. Retention periods will be provided to you in a separate employee privacy notice.

If you ask the Company to delete your personal data before the end of the standard retention period, we will remove the majority of the information we hold about you, including CVs, application information, interview notes, assessment results and any diversity monitoring data.

However, where necessary to apply our re-application rules fairly and consistently, the Company may retain a very limited amount of basic information (such as your name, email address, application date and re-application eligibility markers) for up to six months. This information is used only for the purpose of managing re-application eligibility and is deleted once the six-month period has passed.

9. Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request
• require the Company to change incorrect or incomplete data
• require the Company to delete or stop processing your data where it is no longer necessary
• object to the processing of your data where the Company is relying on legitimate interests as the lawful basis
• ask the Company to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override the Company’s legitimate grounds

If you would like to exercise any of these rights, please contact compliance@sigmalabs.co.uk.

If you believe the Company has not complied with your data protection rights, you can complain to the Information Commissioner.

10. What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.

If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references (where references are required).

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

11. Automated decision-making

Our recruitment processes are not based solely on automated decision-making. However, certain early stages of our recruitment process involve automated decision-making, meaning that some decisions about candidate progression may be made automatically without human involvement.

At these stages, we use automated scoring or eligibility criteria to assess whether a candidate meets the minimum requirements to progress. Candidates whose results do not meet these requirements may not progress further in the recruitment process.

We use automated decision-making in this way to help assess candidates consistently against the same criteria and to reduce the risk of inconsistency or bias at the early stages of recruitment. Final hiring decisions are always made by people, based on a review of the information collected throughout the recruitment process.

You have the right to request human review of an automated decision, to express your point of view, and to challenge a decision. You may exercise these rights by contacting us using the details set out in this notice.

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Terms & Conditions

These Terms of Use set out the terms and conditions upon which any person may view pages of this website.

Definitions

• “The Website”:  corresponding pages accessible at www.sigmalabs.co.uk;
• “The Content”: of pages at the Site;
• “User”, “you”, “your”: any person viewing or using the Site or Content.

Disclaimer

All material published on the website is published in good faith and for information purposes only. We cannot guarantee or warrant representation of accuracy or reliability of such information. There is no guarantee that the contents or operation of the website will be error-free. Although it may be possible to obtain access to other websites from this website, there is no endorsement or responsibility for those websites.

Agreement

This Website Terms of Use Agreement (“Agreement”) governs your access to, and use of, the Sigma Labs Website. The Site is the property of Sigma Labs and this Agreement is between Sigma Labs and any party viewing or otherwise making use of the Site or the Content by accessing and/or using Third Party Processors.

Intellectual Property

All Content, including but not limited to all text, graphics, logos, icons, images, data, graphs, audio, videos, computer programs and other material and information contained on, or utilised in the provision of, the Site is the property of Sigma Labs or its content suppliers and is protected by copyrights, trademarks, trade secrets, or other proprietary rights, and such rights are valid and protected in all forms, media, and technologies existing now or hereinafter developed.

License

Sigma Labs hereby grants you a limited, non-exclusive, non-transferable personal license to use the Site and the Content for, information purposes only. You may print and/or download and store the Content for non-commercial, personal or internal business use (as applicable) only, provided that you retain all copyright and other proprietary notices contained on the Content and comply with these terms of use.

Limitations

Except as expressly authorised herein or otherwise authorised by Sigma Labs in writing, you may not use, copy, distribute, modify or create derivative works from, disclose, display, transmit, or post the Content for any purpose, or in any way exploit any of the Content, in whole or in part. You may not use any META tags or any other “hidden text” using Sigma Labs’s name or trademarks on your website or otherwise, without the express written consent of Sigma Labs. All rights not expressly granted herein are reserved to Sigma Labs and/or its licensors. You acknowledge that your unauthorised use of the Site or the Contents may cause us loss and damage for which an award in damages may not adequately compensate us and that we are, in those circumstances, entitled to apply for suitable equitable relief. This license may be terminated by Sigma Labs at any time upon notification to you, and the license is automatically terminated upon any breach by you of these Terms of Use.

Amendment & Jurisdiction

Sigma Labs reserves the right to amend any of the terms of this Agreement or Content at any time by posting such amendment on the Site. The version of this Agreement available on the Site at the time you visit the Site or use the Content shall apply to such use.

This Site, Agreement and and Dispute shall be governed solely by English Law and the jurisdiction of the Courts of England and Wales.

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Modern Slavery and Human Trafficking Statement

Sigma Labs is committed to acting ethically and with integrity in all its business dealings and relationships. Modern slavery is a crime and a violation of fundamental human rights, and we have established systems and controls to help us to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Business Structure

Sigma Labs is a UK-based professional services provider operating in the Recruit, Train and Deploy sector. Sigma Labs' principal business activities involve recruiting, training and deploying our own permanent IT and business consultants with our clients. They work across a range of technical disciplines, including but not limited to Development and Data. Sigma Labs has dedicated training centres and sales operations located in London. Sigma Labs is a proactive and enthusiastic promoter of diversity, social mobility and inclusion.

Our Policy

At Sigma Labs we believe in the importance of equality in the workplace. Being a responsible corporate citizen is not only the right thing to do, it is good for the longterm viability of our business. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain. We believe employment should be chosen. There must be no forced, bonded or involuntary prison labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.

Our senior staff provide constant support to all members of staff and ensures all employees and Trainees are getting the relevant training and development needed in order for them to achieve all they can here at Sigma Labs.

We pride ourselves highly on promoting human rights within the business and ensure all members of staff are happy and content within their working environment. We encourage weekly catch ups and constant suggestions via our company portal on how we can strengthen the ways in which we protect our employees’ rights and company benefits. We hold our suppliers, business partners and all other stakeholders to the same standards that we hold ourselves. We run a safe and ethical business that extends well beyond Sigma Labs. Our code of conduct is an overview of the guiding principles and values which govern how we make ethical decisions in conducting our business.

Please see below the following steps we have taken and continue to take in adherence to the Modern Slavery Act.

Supply Chain

Our supply chain is not very complex however we work with a vast range of suppliers that provide services across a number of varied categories that range from cyber security, IT, telecoms, technology sales, data analytics and other services which can be seen on our company website. We keep very respectable relationships with our suppliers which allows us to have a good understanding and visibility of our supply chain.

Due to the strong relationships we have with our suppliers, contractors, trainees and consultants we consider the risk of exploitation, human trafficking and breach of human rights very low. Nonetheless we are committed to ensuring such occurrences do not take place within our business or supply chain due to our procedures and due diligence.

Contracts

Our contracts include a provision for all suppliers to warrant that it has not and will not engage in any activity, practice or conduct which would constitute an offence under the Modern Slavery Act 2015.

Policies

All Sigma Labs employees have access to channels in which they can communicate concerns, via local reporting mechanisms or internal whistleblowing procedures, which encourage all staff to report any wrong behaviour or breaches of our policies. Sigma Labs is committed to protecting its employees when disclosing malpractice and we take this very seriously. All employees must be provided with a clear contract of employment which complies with local legislation. All contracts are received before employees join Sigma Labs which gives new employees the opportunity to read through all of our company policies and raise any queries prior to starting, which encourages a smooth onboarding process for all parties.

Sigma Labs hold a zero-tolerance policy on Modern Slavery and are committed to the highest level of ethical standards. All employees are under duty to comply and understand this policy. The prevention, detection and reporting of modern slavery and human trafficking within businesses or any supply chains is the responsibility of those working for Sigma Labs. Employees are encouraged to avoid any behaviour that would suggest a clear breach of this policy

Verification and Risk Assessment

Sigma Labs require a due diligence process of supply chain risk based on international indices, supplier performance and other indicators of suppliers and contractors and have a supporting audit process. Our standard supplier contracts contain Compliance with Laws provisions which oblige the parties to comply with all laws applicable to their activities under the contract.

Audit

Verification of code conformance and assurance through our own supplier audit process including demonstration from our supply chain that they have passed down Sigma Labs’ requirements to their own suppliers and contractors and have supporting audit process.

Internal Training and Review

Sigma Labs ensure that any updates of changes to our code of conduct in relation to modern slavery and human trafficking are fed to all employees and all necessary and/or recommended training takes place. All employees at Sigma Labs are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty.

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Senior Directors and the cross functional team nominated by the business on a regular basis (at least annually) and may be amended from time to time.

The Modern Slavery and Human Trafficking Statement was authored by X. Cai, CFO at Sigma Labs and was last revised on 15th January 2025.