Privacy Notice

Last updated: [October 2026]

1. Who we are

The Pursuit is the trading name of [Registered company name] Ltd, a company registered in England and Wales under company number [●], with its registered office at Lumen House, 12–13 Clerkenwell Green, London EC1R 0QJ (“The Pursuit”, “we”, “us”, “our”).

We are an executive search and recruitment business. We act as an employment agency and employment business under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, and we also provide recruitment consultancy services.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, The Pursuit is the controller of the personal data described in this notice. We are registered with the Information Commissioner’s Office (ICO) under registration number [●].

You can contact us about anything in this notice at:

• Email: [email protected]
• Post: Data Protection, The Pursuit, Lumen House, 12–13 Clerkenwell Green, London EC1R 0QJ

2. Who this notice applies to

This notice explains how we collect and use personal data about:

• candidates, both prospective and placed, for permanent, interim, temporary or contract roles;
• contacts at our current and prospective clients;
• contacts at our suppliers and business partners;
• referees and emergency contacts whose details are given to us by candidates;
• visitors to our website.

3. The personal data we collect

Candidates. Depending on how you engage with us, we may collect: your name and contact details; your CV, employment history, education, qualifications, skills and professional memberships; links to your public professional profiles (such as LinkedIn); your current and desired remuneration and benefits; your career preferences, notice period and availability; interview notes and assessments, including feedback from clients; references; right-to-work documents such as your passport, visa or share code; and correspondence with us by email, phone or video call.

If you are placed in a temporary or contract role through us, we may also collect your date of birth, National Insurance number, bank details, tax and payroll information, and details needed to pay you.

Client and supplier contacts. Your name, job title, employer, business contact details, correspondence with us, and information needed to manage our contract and invoicing.

Website visitors. Your IP address, browser and device type, the pages you view, how you arrived on our site and how you interact with it. We also collect any information you submit through our forms. See section 15 on cookies.

4. Special category and criminal offence data

Some information is more sensitive and receives extra protection under the law. We only collect it where it is relevant to a recruitment process and the law allows it:

• Health or disability information, where you choose to tell us so we can make reasonable adjustments to an interview or recruitment process. We rely on our obligations in the field of employment law and, where appropriate, your explicit consent.
• Diversity and equal opportunities information, such as ethnicity, gender or sexual orientation, only where you provide it voluntarily for equal opportunities monitoring. This is always optional, and we use it in aggregated form where possible.
• Criminal convictions information, only where it is required for a specific role (for example, under the Disclosure and Barring Service framework or a client’s regulatory requirements), and only where the Data Protection Act 2018 permits it.

We hold an appropriate policy document setting out how we protect this data.

5. Where we get your personal data from

We collect most personal data directly from you, for example when you send us your CV, register with us, speak to us, or fill in a form on our website.

We may also obtain it from other sources, including: professional networking sites such as LinkedIn; job boards and online CV databases; your current or former employer’s public website; referees; clients who give us feedback on your interviews; people who recommend you to us; and publicly available sources.

Where we obtain your data from someone other than you, we will give you this notice within one month of obtaining it, or at the latest when we first contact you, and tell you where your data came from.

6. How we use your data and our lawful bases

We only use your personal data where the law allows us to. The lawful bases we rely on are:

• Contract: where processing is needed to enter into or perform a contract with you, such as an agreement to supply you as a temporary worker or a contract for our services with your organisation.
• Legal obligation: where we must process data to comply with the law, such as right-to-work checks, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, tax and payroll obligations, and responding to lawful requests from authorities.
• Legitimate interests: where processing is necessary for our legitimate business interests, or those of a third party, and those interests are not overridden by your rights and interests (see section 7).
• Consent: where we have asked for your consent for a specific purpose. In particular, we will not send your CV or identify you to a client without first telling you about the role and obtaining your agreement. You can withdraw consent at any time, without affecting processing that took place before you did.

In summary, we use your data to:

7. Our legitimate interests

As a search firm, building and maintaining a database of candidates and client contacts is central to our business. Our legitimate interests include identifying and approaching suitable candidates for roles; matching candidates to client requirements; maintaining relationships with candidates and clients over time; developing our business; keeping our systems and website secure; and establishing, exercising or defending legal claims.

We have balanced these interests against your rights and expectations. You can ask us for more information about this assessment, and you can object to processing based on legitimate interests at any time (see section 13).

8. Marketing

We may send you information about roles, market insights, events or our services that we believe will interest you. To individuals at businesses, we may do this on the basis of our legitimate interests. To individuals in a personal capacity, we will only send electronic marketing where you have consented, or where you have previously engaged with us about similar services and did not opt out.

Every marketing message will include a simple way to unsubscribe, and you can opt out at any time by emailing [email protected].

9. Automated decision-making

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you. We use technology to search and organise our database, for example by searching for candidates with particular skills, but a member of our team is always involved in decisions about whether to contact you, shortlist you, or introduce you to a client.

10. Who we share your data with

We share personal data only where necessary and with appropriate safeguards:

• Clients: to introduce candidates for roles, always with the candidate’s prior agreement.
• Candidates: to arrange interviews and engagements (for example, a client contact’s name and contact details).
• Referees and verification providers: to obtain references and carry out checks you have been told about.
• Service providers acting on our behalf: including our CRM and IT providers, cloud hosting, email and communication services, payroll and payment providers, background screening providers, and professional advisers such as accountants, lawyers and insurers. They may only use your data on our instructions.
• Authorities and regulators: such as HMRC, the Home Office or the ICO, where the law requires it.
• A buyer or successor: if we sell, restructure or merge our business, personal data may be transferred to the new owner, who will be bound by equivalent obligations.

We do not sell your personal data.

11. International transfers

Some of our service providers, and some clients for international roles, may be located outside the UK. Where we transfer personal data outside the UK, we make sure it is protected by one of the safeguards recognised by UK law, such as:

• a country covered by UK adequacy regulations (including the European Economic Area);
• the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses;
• another transfer mechanism permitted under the UK GDPR.

You can ask us for more information about the safeguards in place for a particular transfer.

12. How long we keep your data

We keep personal data only for as long as we need it for the purposes set out in this notice, including to meet legal, accounting or reporting requirements. As a general guide:

• Candidates we have not placed: [2] years from our last meaningful contact with you, after which we will either ask whether you want us to keep your details or delete or anonymise them.
• Candidates we have placed and temporary or contract workers: [6] years from the end of the placement or engagement, to meet our legal, tax and contractual obligations.
• Client and supplier contacts: [6] years from the end of our business relationship.
• Right-to-work records: for the period required by Home Office rules.
• Website analytics data: up to [26] months.
• Complaints records: [3] years from the complaint being closed.

Where you ask us to delete your data, we may keep a minimal record (such as your name and the fact you asked us not to contact you) so we can respect your request in future.

13. Your rights

Under the UK GDPR you have the right to:

• access the personal data we hold about you and receive a copy;
• rectification of inaccurate or incomplete data;
• erasure of your data in certain circumstances;
• restrict our processing in certain circumstances;
• object to processing based on our legitimate interests, and to direct marketing at any time;
• data portability, to receive data you gave us in a structured, machine-readable format, or have it sent to another organisation, where processing is based on consent or contract;
• withdraw consent at any time, where we rely on consent;
• not be subject to solely automated decisions with legal or similarly significant effects.

To exercise any of these rights, contact [email protected]. We may need to verify your identity before responding. We will respond within one month, which may be extended by up to two further months for complex requests, in which case we will tell you why. When responding to access requests, we will carry out a reasonable and proportionate search for your personal data. There is normally no fee.

14. Complaints

If you are unhappy with how we have handled your personal data, please tell us first so we can try to put it right. You can complain by email to [email protected] or by post to the address in section 1. You don’t need to use any particular form or legal wording.

We will acknowledge your complaint within 30 days, look into it without undue delay, keep you updated on our progress, and tell you the outcome.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator:

• Website: https://ico.org.uk/make-a-complaint/
• Phone: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

15. Cookies and similar technologies

Our website uses cookies and similar technologies. We use:

• Strictly necessary technologies, which are needed for the site to work (for example, to remember your cookie choices or keep forms secure). These do not require your consent.
• Analytics technologies, which help us understand how visitors use our site so we can improve it. [Where these are used only to produce aggregate statistics on our behalf, we may rely on the statistical purposes exemption, in which case we will tell you about them and give you a simple way to object. Otherwise we will ask for your consent.]
• Any other non-essential technologies, such as advertising or social media tracking, which we will only use with your consent.

You can change your choices at any time through the cookie settings link at the bottom of every page. See our [Cookie Policy] for full details of the cookies we use.

16. Security

We use appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access, including access controls, encryption where appropriate, and confidentiality obligations on our staff and service providers. If a personal data breach occurs that is likely to result in a high risk to you, we will tell you without undue delay.

17. Links to other websites

Our website may link to other websites, such as job boards or social media. Those sites have their own privacy notices, and we are not responsible for how they handle your data.

18. Changes to this notice

We may update this notice from time to time. The latest version will always be on this page, with the date of the last update at the top. Where changes are significant, we will let you know by email where appropriate.