How We Handle Your Data.
Recruitment runs on trust. This policy explains exactly what data we collect, why we collect it, how long we keep it, and the rights you have at every step.
Last updated: [DATE]
01
Introduction
Elite Executive Recruitment (“Elite”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and disclose personal data when you visit our website, engage with our services, apply for a role through us, or are sourced by us as a potential candidate.
This policy is issued by Elite Executive Recruitment Ltd, registered in England, with a registered office at 71-75 Shelton Street, London WC2H 9JQ, United Kingdom.
For any privacy-related questions, please contact us at help@elitexrecruit.com.
02
Who this policy applies to
- Candidates — individuals whose personal data we process in connection with current or future employment opportunities.
- Clients — individuals at organisations who engage us to fill roles.
- Website visitors — anyone who uses the Elite website.
- Suppliers and other contacts — individuals at organisations we work with.
03
The personal data we collect
Candidate data
- Name, contact details (email, phone, address, LinkedIn profile)
- Date of birth and gender (where relevant for diversity monitoring)
- Right-to-work documentation
- CV, employment history, education, qualifications, and references
- Current and expected salary, benefits, and notice period
- Photographs (where you provide them, e.g. on LinkedIn)
- Records of our communications with you
- Information from third-party sources, including LinkedIn, professional networks, public databases, and referrals
- Special category data (such as health information or ethnicity), only where necessary, lawful, and with your explicit consent
We do not request or process criminal record information unless specifically required for a role and authorised by law.
Client data
- Name, job title, employer, and business contact details
- Records of communications, briefs, and commercial discussions
- Information you provide about hiring requirements
Website visitor data
- IP address, device type, browser type, and operating system
- Pages visited, time on site, referral source
- Cookie data (see Section 11)
04
How we collect personal data
- Directly from you — when you submit a CV, contact us via our website, respond to outreach, or attend a meeting.
- From your employer or referee — when references are provided.
- From third-party sources — including LinkedIn, professional networks, online portfolios, public business registers, and recruitment databases we lawfully access.
- From referrals — when an existing contact recommends you for a role.
- Automatically — through cookies and analytics tools when you use our website.
05
Lawful bases for processing
Under the UK General Data Protection Regulation (UK GDPR), we rely on the following lawful bases:
| Activity | Lawful basis |
|---|---|
| Sourcing and approaching candidates from public/professional sources | Legitimate interests — to provide recruitment services |
| Processing CVs and applications submitted to us | Legitimate interests / Performance of a contract |
| Sharing candidate details with prospective employers | Legitimate interests, with your knowledge |
| Marketing communications to clients | Legitimate interests / Consent |
| Special category data (e.g. health, ethnicity) | Explicit consent |
| Compliance with legal obligations (tax, employment law) | Legal obligation |
You have the right to object to processing based on legitimate interests at any time (see Section 9).
06
How we use your personal data
- Identify and assess candidates for current and future roles
- Communicate with candidates and clients about opportunities and assignments
- Submit candidate details to clients with your knowledge
- Manage our relationship with clients
- Maintain our internal candidate and client database
- Comply with legal, regulatory, and contractual obligations
- Operate, secure, and improve our website
- Send marketing communications where you have not opted out
- Conduct equal opportunities and diversity monitoring (anonymised)
07
Sharing your personal data
- Prospective employers (clients) — where we believe a role is relevant to you. We only share information necessary to assess your suitability.
- Referees — where you have given them as references.
- Third-party service providers — including our applicant tracking system, email and CRM providers, IT and hosting providers, and professional advisors. These are bound by contractual data processing agreements.
- Regulators, law enforcement, and legal authorities — where legally required.
- Acquirers — in the event of a sale, merger, or acquisition of our business.
We do not sell your personal data to third parties.
International transfers
Some of our service providers are based outside the UK. Where personal data is transferred internationally, we rely on UK Government adequacy decisions, the UK International Data Transfer Agreement (IDTA), or Standard Contractual Clauses (SCCs) to ensure equivalent protection.
08
How long we keep your data
We retain personal data only for as long as necessary for the purposes outlined in this policy.
| Data type | Retention period |
|---|---|
| Candidate records (active engagement) | Duration of the engagement plus 6 years |
| Candidate records (no recent engagement) | Reviewed every 2 years; deleted if no continuing relevance |
| Client records | Duration of the relationship plus 6 years |
| Website analytics | 26 months |
| Marketing contact data | Until consent is withdrawn or the contact opts out |
| Records required by law (e.g. financial, tax) | As required by applicable law (typically 6 years) |
You can request deletion at any time (see Section 9).
09
Your rights
Under UK GDPR, you have the following rights:
- Right of access — request a copy of the personal data we hold about you.
- Right to rectification — ask us to correct inaccurate or incomplete data.
- Right to erasure — ask us to delete your data (“right to be forgotten”).
- Right to restrict processing — ask us to limit how we use your data.
- Right to data portability — ask us to provide your data in a machine-readable format.
- Right to object — object to processing based on legitimate interests, including profiling and direct marketing.
- Right to withdraw consent — where we rely on consent, you can withdraw it at any time.
- Rights regarding automated decision-making — request human review of automated decisions.
To exercise any of these rights, please email help@elitexrecruit.com. We will respond within one calendar month.
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113 — Web: ico.org.uk
If you are unhappy with how we handle your data, you have the right to complain to the UK Information Commissioner’s Office.
10
Data security
We take the security of personal data seriously. We have implemented technical and organisational measures designed to prevent unauthorised access, accidental loss, alteration, or disclosure.
- Encryption of data in transit (HTTPS/TLS) and at rest where appropriate
- Access controls and authentication on all systems
- Regular review of supplier security standards
- Staff training on data protection
- Incident response procedures
No system is completely secure. While we use reasonable measures to protect your data, we cannot guarantee absolute security.
11
Cookies
Our website uses cookies and similar technologies to provide essential functionality, analyse usage, and improve performance.
- Strictly necessary cookies — required for the website to function.
- Analytics cookies — to understand how visitors use the site (e.g. Google Analytics).
- Functional cookies — to remember your preferences.
You can manage cookie preferences through our cookie banner or by adjusting your browser settings. Disabling certain cookies may affect website functionality.
12
Marketing communications
We may send marketing communications to clients and prospective clients about our services where we have a legitimate interest or where you have consented.
You can opt out of marketing at any time by clicking the “unsubscribe” link in any marketing email or emailing help@elitexrecruit.com. We will action opt-out requests promptly.
13
Third-party links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We are not responsible for the privacy practices of any third party — please review their privacy policies before submitting any personal data.
14
Children
Our services are not directed at children under 16, and we do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us and we will delete it.
15
Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date at the top of this policy will indicate when the most recent changes were made. We encourage you to review this policy periodically.
For material changes affecting how we use your data, we will provide additional notice where appropriate.
16
Contact us
If you have any questions about this Privacy Policy or how we handle your personal data, please get in touch.
Get in touch
Elite Executive Recruitment Ltd
