Impact Talent Ltd. – Privacy Notice

This Privacy Notice sets out the basis on which Impact Talent Ltd. will process personal information provided to us; this information is also referred to as ‘personal data’. Impact Talent Ltd. is referred to throughout as “we”, “us”, “our” and “ours”.

Impact Talent Ltd. processes personal data in accordance with the UK GDPR, the Data Protection Act 2018, and all other applicable UK data protection legislation.

At Impact Talent Ltd., we take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes.

We provide executive search and recruitment services, supporting individuals seeking new opportunities and organisations seeking to hire senior-level or specialist talent. For the purposes of this Privacy Notice, our commercial activities and services are referred to as ‘Recruitment Services’, and our actual or potential hiring customers are referred to as ‘Clients’.

The person responsible for data protection matters within our organisation is the Impact Talent Data Protection Lead, who can be contacted at hello@impact-talent.co.uk.

If you do not wish us to process your personal data in accordance with this policy, then please do not provide it to us. Please refer to Section 4 ’Your rights‘ in respect of data that we already hold or which we receive from third parties.

Section 1: Candidates Using Our Recruitment Services

Personal data we collect or receive may include:

• Name

• Address

• Contact details (email, phone)

• Date of birth

• Employment history and career information

• Education, qualifications, and skills

• Visa or right-to-work information

• Passport (where required)

• Referee information

• Notes from interviews, conversations, or assessments

• Information from references or background checks

• Your marketing preferences

• Sensitive personal data (see SPD section below)

We may obtain your data from you directly, from Clients, from colleagues or former employers, from publicly available sources, online job sites, social media platforms such as LinkedIn, or through conversations, meetings, or submissions via our website.

Where we obtain your data from a third-party source such as a job board, we will notify you of the source when we first contact you.

How we use your personal data

The processing of your personal information may include:

• Collecting and storing your personal data

• Discussing suitable opportunities with you

• Assessing your suitability for senior or specialist roles

• Introducing you to actual or potential Clients

• Providing advice, guidance, or market insights

• Contacting you about future opportunities

• Maintaining records of our interactions

• Quality assurance, compliance, and training

• System backups for business continuity

• Providing information to regulatory bodies or professional advisers

• Marketing our Recruitment Services (with opt-out rights)

We may also contact you with:

Insights, market updates, or information about our services where we believe they may be relevant to your professional role. You may unsubscribe or update your marketing preferences at any time.

Why we process your data

1. Contractual requirements

To deliver Recruitment Services or to enter into a contract with you or a Client.

2. Legal obligations

Including identity verification, suitability checks, fraud prevention, regulatory reporting, and compliance with statutory retention requirements.

3. Legitimate interests

We process personal data where necessary for the legitimate interests of running an executive search business, including:

• Candidate headhunting

• Emailing passive candidates

• Reaching out to senior leaders globally

• Reviewing suitability for opportunities

• Maintaining accurate business records

• Protecting our reputation

• Conducting market mapping and research

• Quality review and training

• Using software tools to support communication, market research and administrative processes

• Personalising your experience

We do not use fully automated AI to make hiring decisions about candidates. Software may support shortlisting or research, but human judgement always determines outcomes.

We may continue to process personal data for as long as reasonably required to fulfil these interests.

Sensitive Personal Data (SPD)

We request that you do not provide SPD unless necessary. If provided, we may process it only where:

• You have explicitly consented

• It is necessary for suitability or work capacity assessment

• It is required under employment or social protection law

• It is needed to establish, exercise, or defend legal claims

Who we share personal data with

Your information may be shared with:

• Clients seeking to hire senior or specialist talent

• Third-party service providers supporting our Recruitment Services

• Legal and professional advisers

• Regulatory authorities

• Insurers

We may engage third-party service providers — such as CRM systems, email platforms, IT support, cloud storage, and analytics providers — to process personal data on our behalf. All such providers act under appropriate contractual safeguards.

We do not sell personal data to any third parties.

Automated decision making

We may use software to identify candidates with specific skills or experience. If you believe an automated assessment has been made incorrectly, you may request an explanation or human review.

Section 2: Individuals Working for Clients or Suppliers

We may process your contact details and communication history in the course of delivering Recruitment Services. This includes:

• Storing your contact information

• Communicating with you about searches or hiring activity

• Sharing information with candidates or other parties where necessary

• Maintaining records for compliance, quality assurance, or dispute resolution

• Providing information to regulatory bodies or advisers

Client and supplier contact information may be retained for as long as we maintain a business relationship or have a legitimate interest in keeping a record of past communications.

Section 3: All Personal Data

International transfers

We operate globally, particularly across Africa, the Middle East, Asia, and Latin America. As such, data may be transferred outside the UK or EEA.

Where this occurs, we will:

• Use jurisdictions with an adequacy decision or

• Implement appropriate safeguards such as SCCs or the ICO’s IDTA

• Assess risks and apply suitable mitigation measures

Details are available upon request at hello@impact-talent.co.uk.

Website hosting and analytics

Our website is hosted by Squarespace, which processes:

• Website analytics

• Form submissions

• Technical data (IP address, device, browser type)

Squarespace processes this data on our behalf in accordance with its own privacy and security standards.

Cookies

We use cookies to improve website performance and personalise your experience. You may manage or disable cookies through your browser settings or via our website cookie banner.

Retention of data

We retain data for no longer than necessary, typically up to 6 years from last engagement.

However:

Where candidates operate in specialist markets where skills remain in demand long-term, we may retain necessary professional information beyond 6 years, unless you request deletion.

Client and supplier data may be retained as long as we maintain a commercial relationship or legitimate interest.

Security

We take appropriate technical and organisational measures to secure personal data and prevent unauthorised access.

Changes to this Privacy Notice

We may update this notice to reflect changes in law or business practice. Where relevant, we will notify you.

Section 4: Your Rights

You have the right to:

• Request access to your personal data

• Request rectification of inaccurate data

• Request deletion where continued processing is unjustified

• Object to processing based on legitimate interests

• Request restriction of processing

• Object to direct marketing

• Request data portability (where applicable)

• Withdraw consent at any time

• Lodge a complaint with the ICO

We will respond to valid requests within one month, in accordance with the UK GDPR.

You may update your marketing preferences or unsubscribe at any time via communication links or by contacting us directly.

To exercise your rights, email hello@impact-talent.co.uk.

Complaints

If you are dissatisfied with how your data is processed, you may contact our Data Protection Lead at hello@impact-talent.co.uk.
You may also raise concerns with the Information Commissioner’s Office.