Legitimate Interest Assessment

Legitimate Interest Assessment (LIA) – Summary

Last updated: November 2025

Nova processes certain professional information about individuals (“candidates”) on the basis of legitimate interest under Article 6(1)(f) GDPR. This summary explains why this legal basis is appropriate for the operation of the Nova Recruiter platform.

1. What data we process and where it comes from

We process business-related professional information only, such as name, job title, employer, education, skills, and publicly disclosed work email.

This information comes from:

• Publicly accessible online sources; and
• Licensed professional-data providers (e.g., ContactOut Limited) that collect data lawfully as independent controllers.

We do not process sensitive data, behavioural data, or information from private social profiles.

2. Our legitimate interest

Nova operates a professional recruitment platform used by verified employers and recruiters to identify qualified candidates for genuine job opportunities.

Our legitimate interest is to:

• enable effective talent discovery for employers,
• improve matching between candidates and job opportunities, and
• maintain the accuracy and quality of our professional dataset.

This is a recognised and lawful interest under GDPR, and is common in professional networking and recruitment services.

3. Why the processing is necessary

To provide accurate and relevant search results, Nova must index and organise professional information from public and licensed sources.

There is no equally effective, less intrusive alternative (for example, consent at collection would not be feasible or proportionate for publicly available data).

4. Impact on individuals and safeguards

We use only low-risk, professional data and apply strict safeguards:

• Access is restricted to authenticated recruiter clients under contract.
• Individuals can request deletion or object to processing at any time.
• No sensitive data is included.
• No data is made publicly searchable outside Nova Recruiter.
• Human oversight is required for any outreach or decision-making.
• Data is stored securely and reviewed for accuracy.

These measures significantly limit the impact on individuals’ rights and freedoms.

5. Outcome of the LIA

After assessing our purpose, the necessity of the processing, and its impact on individuals, Nova concludes that:

• our legitimate interest in providing a recruitment-search platform is strong and lawful,
• the data processed is professional, limited, and low-risk, and
• robust safeguards ensure minimal impact on individuals.

Therefore, processing such data under Article 6(1)(f) GDPR (Legitimate Interest) is appropriate.

6. Your rights

You may at any time:

• Object to the use of your professional data.
• Request deletion.
• Request access or correction.

To exercise your rights, please contact: privacy@novatalent.com