Pure DC has a zero-tolerance approach to bribery and corruption in all its business dealings and relationships. It is our policy to conduct business with honesty and integrity and to avoid any action that may be, or may be perceived to be, in breach of anti-bribery and corruption policies and regulation and we expect the same from all those with whom we do business.

Pure DC will comply with the UK Anti-Bribery Act 2010 and the US Foreign and Corruption Practices Act, together with the anti-bribery regulation and laws of each jurisdiction in which we operate. All Pure DC personnel, suppliers, consultants, contractors, agents, and other business partners are prohibited from soliciting, accepting, offering, promising, making, authorising or providing (directly or indirectly) any payments, gifts, or transfers of anything of value to any person (including Public Officials) in order to influence, induce or reward that persons improper performance of their function or activity or any official action or decision for Pure DC’s benefit.

Pure DC has developed procedures that are proportionate to the specific risks faced by the business and the nature, scale, and complexity of our operations. This includes comprehensive due diligence processes to understand the background and reputation of parties with whom we do business.

Anyone found to be engaging in bribery or corruption or otherwise breaching Pure DC’s Anti-Bribery and Corruption policy and related procedures will be subject to disciplinary action and termination of contract.

We are committed to providing a working environment free from harassment, bullying and victimisation, and ensuring all employees are treated, and treat others (including the employees of our customers, consultants and contractors) with dignity and respect.

We will not tolerate harassment, bullying or victimisation of any kind.

You have the right to feel safe, welcome and comfortable as you conduct your day-to-day work. You have the right to enjoy a work environment that is free from harassment, bullying and victimisation. You should feel empowered to raise challenges and make complaints if you experience any behaviour that falls below this standard.

All allegations of harassment, bullying and victimisation will be investigated and, if appropriate, disciplinary action will be taken. We will also not tolerate a person being victimised for making allegations of bullying or harassment in good faith or supporting someone to make such a complaint.

Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority but can include both personal strength and the power to coerce through fear or intimidation.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

We are passionate about creating an inclusive workplace that promotes diversity and where all of our people feel valued, welcome and comfortable bringing their full, authentic selves to work.

We embrace uniqueness because we know that each employee’s experience, perspective, and viewpoint are critical to creating Data Centres that engage our customers. We believe that different perspectives make us stronger and drive innovation, creativity and better results.

We adopt a zero-tolerance approach to discrimination on any of the protected grounds in the Equality Act 2010.

We believe it is wrong to discriminate against any individual on any grounds, and in any form and believe that everyone regardless of their background should be treated with dignity and respect. This includes: our people, meaning our employees and those with whom we interact (e.g. suppliers and customers) and other stakeholders.

We aim to create a working environment in which all individuals are able to make the best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.

We promote equal opportunities and make sure no applicant receives less favourable treatment on the grounds of gender, marital status, nationality, ethnicity, age, sexual orientation, responsibilities for dependants, physical or mental disability. We select candidates for interview based purely on their skills, qualifications, experience and potential, and therefore we strongly encourage suitably qualified applicants from a wide range of backgrounds to apply and join Pure Data Centres Group.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Pure DC has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within the business or in any of our supply chains.

Pure DC is a UK-based organisation specialising in the design, construction, and operation of data centres across multiple global regions. We have operations across the UK, Europe, the Middle East, and Asia. Our organisational structure includes regional offices, and a network of subsidiaries, and our key supply chains include:

• Construction materials and services
• Mechanical and electrical equipment
• IT infrastructure and hardware
• Facilities management and cleaning services
• Professional services (legal, financial, consultancy)

Given the global nature of our operations, we recognise the risk of modern slavery in certain regions and sectors, particularly in construction and manufacturing. Our supply chains span multiple countries, and we recognise that some of these supply chains may carry a higher risk of modern slavery, particularly those involving outsourced labour or suppliers operating in high-risk regions, and we are committed to managing these risks proactively. Pure DC is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and require compliance with all applicable national and international anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force. We also expect that our contractors, suppliers and other business partners will hold their own suppliers to the same high standards.

To support these commitments, Pure DC has implemented the following policies:

• Anti-Slavery and Human Trafficking Policy
• Code of Conduct
• Whistleblowing Policy
• Group Procurement Policy
  These policies are reviewed regularly and are communicated to all employees and key suppliers.

Pure DC undertakes due diligence when considering taking on new suppliers and regularly reviews its existing supply chains. Our due diligence and supplier onboarding processes include assessing risks of modern slavery, focussing on geographic and sector specific risks. We require high-risk suppliers to provide evidence of their anti-modern slavery practices, including their own policies, declarations of compliance, and where appropriate, conducting audits or site visits.

To measure the effectiveness of our efforts to combat modern slavery, we monitor the number of supplier audits completed, training completion rates, and any reported incidents of non-compliance. These indicators are reviewed annually and used to inform improvements to our policies and practices.

Training is provided to all staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. Training is refreshed annually and updated to reflect emerging risks and best practices. In addition, our code of conduct establishes a set of common standards and business behaviours that everyone at Pure DC should follow, including our support of the principles set out in the United Nations Universal Declaration of Human Rights.

This statement and the Pure DC Anti-Slavery and Human Trafficking Policy have been approved by the Board of Directors and are reviewed annually. They apply to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners. This statement covers the financial year ended 31 December 2024, and covers all Pure DC subsidiaries.

This statement was reviewed and approved by the Board of Directors on 30 June 2025.

Pure Data Centres Group (collectively referred to as “Pure DC“, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice describes the types of personal data that Pure DC will collect throughout the recruitment process, including through our website and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

It is important that you read this privacy notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Controller

Pure DC is the controller (as defined in the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018), and responsible for your personal data.

This privacy notice is issued on behalf of the Pure Data Centres Group of companies so when we mention “Pure DC”, “we”, “us” or “our” in this privacy notice, we are also referring to the relevant Pure Data Centres Group company which may be responsible for processing your data. The local Pure DC entity which seeks to fill a position for which you have applied, and which would be the employing entity in case you were offered employment, will, as a rule, be the controller, responsible for the processing of your personal data.

Contact details

If you have any questions about this privacy notice or our privacy practices, please fill in the request form here for further details.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We will keep this privacy notice under regular review.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes title, first name, last name, date of birth, nationality, country of birth and right to work documentation such as your passport or other related identity documentation.
• Contact Data includes postal address, email address and telephone numbers.
• Educational Data includes academic and vocational qualifications, skills and competencies.
• Employment Data includes your resume or CV, remuneration and benefits package and other documents that support your job application.
• Background Data includes reference letters, the results from any pre-employment screening we may ask you to complete and personal information about you from a publicly available source that you control (such as a job board, job application or a career-based social media platform).
• Diversity and equal opportunities Data includes health details (including any disabilities that affect your ability to perform your work) and information about your ethnic origin.
• Financial Data includes banking details (if you are successful).
• Any other information you voluntarily provide to us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Diversity and Equal Opportunities Data for the purposes of monitoring compliance with our Equality, Diversity and Inclusion Policy and anti-discrimination legislation. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect Special Categories of Personal Data (as defined in the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may also collect information about criminal convictions and offences. We will only process such special categories of data for the purpose of assessing your working capacity, your suitability for the particular job post in question and equal opportunity monitoring and reporting. We will only process such special categories of data in such a manner and to the extent necessary for the aforesaid purpose. Since we will assess your working capacity and your suitability for the specific job post which you apply for, we would kindly ask you to refrain from making available to us any information that is not relevant for the purpose of assessing your working capacity and suitability for the job post which you are applying for.

3. How is your personal data collected?

We mainly collect personal data directly from you during the recruitment process e.g., in the forms you are asked to complete on our website or in interviews. Further information may be provided to us by third parties (for example, recruitment agencies, referees or background check providers).

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• In order to assess your application prior to entering an employment contract with you and pursuant to laws to which Pure DC is subject (e.g., in relation to equal opportunities).
• Where we need to comply with a legal obligation.

Please consider that if you are unable to provide us with the information requested, we may be unable to assess your appropriateness for the job applied for or to communicate with you.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Internal Third Parties as set out in the Glossary.
• Service Providers that are a necessary part of our data processing activities, as further set out in the Glossary. Insofar as our service providers are processors on our behalf, we will have contracts, policies and procedures in place to ensure these companies safeguard personal data entrusted to them, and to only use it under our instructions and for the purposes outlined in this notice.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• Third parties where we have a legal duty to make such disclosure.
• Third parties where we are legally permitted and it is necessary for the handling of contractual relations with yourself or for the execution of precontractual actions effected in response to your enquiry.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We share your personal data within the Pure Data Centres Group. This may involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal Third Parties Other companies in the Pure Data Centres Group who provide IT and system administration services and undertake leadership reporting may require access to your personal data.

Service Providers Includes computer centres which store our website and databases, IT service providers which maintain our systems, other service providers, and corporate consultants.

12. Your legal rights

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Pure DC is committed to providing an open, honest, transparent, and safe working environment where our employees, contractors, consultants, suppliers, and other business partners can report any concerns or malpractice.

All employees, contractors, consultants, suppliers, and other business partners are encouraged to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated. Pure DC provides various means to raise concerns, including an independent and confidential reporting hotline. Full details are available in Pure DC’s Whistleblowing policy.

All disclosures in accordance with our Whistleblowing policy will be treated seriously, and promptly and fairly investigated. Whistleblowers will not suffer any detrimental treatment as a result of raising a genuine concern.