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ICO Appropriate Policy Document

Last updated: 01/10/2026

This document sets out how Walter Everett Ltd processes special category personal data (such as data revealing health conditions relevant to reasonable adjustments, or equal opportunities monitoring data provided voluntarily) in compliance with Article 9 of UK GDPR and the Data Protection Act 2018.

Special category data is only processed where a candidate has explicitly provided it, and only for the purpose it was given for - for example, arranging a reasonable adjustment for an interview. It is never used to make automated decisions about a candidate's suitability for a role.

Such data is retained only for as long as necessary for that purpose, and is subject to the same security and access controls described in our Privacy Policy.