PHIPPS CAMERON RECRUITMENT LIMITED PRIVACY STATEMENT

Introduction

Phipps Cameron Recruitment Limited is committed to protecting and respecting your privacy.

This Privacy Statement explains how we collect, use, store, transfer and protect personal data relating to:

·        candidates and prospective candidates;

·        clients and prospective clients;

·        referees;

·        suppliers and service providers; and

·        visitors to our website.

This Privacy Notice is intended to comply with:

·        the UK General Data Protection Regulation (UK GDPR);

·        the EU General Data Protection Regulation (EU GDPR), where applicable;

·        the Data Protection Act 2018;

·        the Privacy and Electronic Communications Regulations 2003 (“PECR”);

·        the Data (Use and Access) Act 2025

·        International laws – where applicable

1.       Who We Are and How to Contact Us

Data Controller: Phipps Cameron Recruitment Limited
Address: Level 2, Lucent, 1 Sherwood Street, London W1F 7BL
Telephone:+44 (0) 203 757 1100
Email: dataprotection@phippscameron.com
ICO Registration Number: ZA046987

EU Representative (for EEA data subjects):
Corinna Taylor – dataprotection@phippscameron.com

Our supervisory authority is currently the Information Commissioner’s Office (ICO), which is transitioning to the Information Commission under the Data (Use and Access) Act 2025.

2.      The Data We Collect

We collect and process different categories of data depending on the relationship:

Candidates and Prospective Candidates

We may collect:

·        name, address, telephone number and email address;

·        CVs, employment history, qualifications and professional experience;

·        salary, compensation and benefits information;

·        interview notes and recruitment assessments;

·        right-to-work and immigration documentation;

·        references and referee contact details;

·        psychometric or skills assessment results;

·        diversity and equal opportunities information;

·        health information relevant to workplace adjustments;

·        criminal conviction information where legally permitted and role-relevant;

·        publicly available professional information, including LinkedIn profiles.

Clients and Prospective Clients

We may collect:

·        business contact information;

·        job titles and organisational information;

·        communications and engagement history;

·        hiring requirements and feedback.

Suppliers and Service Providers

We may collect:

·        business and contact information;

·        payment and contractual details.

Website Users

We may collect:

·        IP address and device information;

·        browser and usage information;

·        cookie and analytics data;

·       information submitted through website forms

3.      How We Collect Personal Data

We collect personal data:

·        directly from you;

·        from publicly available professional sources;

·        from clients;

·        from referees;

·        from former employers or educational institutions;

·        from background screening providers;

·       through our website and recruitment systems.

4.     Purposes Of Processing

We process personal data to:

·        provide recruitment and executive search services;

·        assess suitability for employment opportunities;

·        present candidate profiles to clients;

·        communicate regarding vacancies and recruitment opportunities;

·        verify qualifications and right-to-work status;

·        undertake background and reference checks;

·        manage contractual relationships;

·        maintain business records;

·        comply with legal and regulatory obligations;

·        monitor equality and diversity;

·        improve our services and website functionality;

·        conduct business development and marketing activities where permitted by law;

·        maintain security and prevent fraud.

5.      Legal Bases For Processing

We rely on one or more of the following lawful bases:

Legitimate Interests

Including:

·        recruitment and executive search activities;

·        candidate sourcing;

·        client relationship management;

·        business development;

·        fraud prevention;

·        internal administration.

Where we rely on legitimate interests, we carry out balancing assessments to ensure our interests are not overridden by your rights and freedoms.

Performance of a Contract

Where processing is necessary:

·        to take steps at your request prior to entering into a contract; or

·        to perform contractual obligations.

Legal Obligation

Including compliance with:

·        employment law;

·        immigration law;

·        anti-discrimination obligations;

·        tax and accounting requirements;

·        regulatory obligations.

Consent

We rely on consent where legally required, including for:

·        certain electronic marketing communications;

·        certain categories of special category personal data.

You may withdraw consent at any time.

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6.     Special Category And Criminal Offence Data

We may process limited amounts of special category personal data, including:

·        health data relating to workplace adjustments;

·        diversity monitoring information.

We process such data only where a lawful condition under Article 9 UK GDPR/EU GDPR applies, including:

·        explicit consent;

·        employment, social security and social protection obligations;

·        substantial public interest conditions where applicable.

Where we process criminal offence data, we do so only:

·        where legally permitted;

·        where relevant and proportionate to the role;

·        subject to appropriate safeguards and retention controls.

We maintain an Appropriate Policy Document where required under the Data Protection Act 2018.

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7.     Automated Decision-Making And Profiling

We may use recruitment technologies, database search tools and filtering methods to assist recruitment processes.

However:

·        recruitment decisions are not made solely by automated means;

·        meaningful human review forms part of decision-making processes.

You have the right to object to profiling and to request further information regarding automated processing.

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8.     Sharing Personal Data

We may share personal data with:

·        clients and prospective employers;

·        IT and cloud service providers;

·        applicant tracking system providers;

·        background screening providers;

·        payroll and professional advisers;

·        regulators, law enforcement agencies and courts where legally required.

We do not sell personal data.

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9.     International Transfers

Personal data may be transferred outside the United Kingdom or European Economic Area, including to jurisdictions that may not provide the same level of data protection.

Where this occurs, we implement appropriate safeguards, including:

·        the UK International Data Transfer Agreement (IDTA);

·        the UK Addendum to the EU Standard Contractual Clauses;

·        European Commission Standard Contractual Clauses;

·        transfer risk assessments;

·        supplementary technical and organisational safeguards where appropriate.

Copies of relevant safeguards may be requested using the contact details in this notice.

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10.   Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including for legal, regulatory, tax, accounting and legitimate business purposes.

Typical retention periods include:

·        candidate records: generally up to 24 months following last meaningful contact;

·        client and business relationship records: generally up to 6 years following the end of the relationship;

·        financial and tax records: generally 6 years;

·        marketing suppression records: as necessary to maintain opt-out preferences.

Retention periods may be extended:

·        where required by law;

·        where claims may arise;

·        where ongoing business relationships exist.

11.     Your Rights

Subject to applicable law, you may have the right to:

·        access your personal data;

·        request correction of inaccurate data;

·        request erasure of your data;

·        restrict processing;

·        object to processing based on legitimate interests;

·        object to direct marketing;

·        request portability of certain personal data;

·        withdraw consent;

·        request information regarding automated decision-making.

You may exercise your rights by contacting: dataprotection@phippscameron.com

We may request proof of identity before responding.

12.   Complaints

If you have concerns regarding our processing of personal data, please contact us first.

You also have the right to lodge a complaint with:

·        the UK Information Commissioner’s Office; or

·        your local supervisory authority within the EEA, where applicable.

13.   Security

We implement appropriate technical and organisational security measures, including:

·        access controls;

·        encryption where appropriate;

·        secure hosting environments;

·        confidentiality obligations;

·        staff training;

·        monitoring and incident management procedures.

14.    Cookies And Website Tracking

Our website uses cookies and similar technologies.

Further information regarding:

·        cookie categories;

·        analytics technologies;

·        consent preferences; and

·        managing cookies

See our Cookie Notice: https://careers.phippscameron.com/cookie-details.

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15.   Changes To This Privacy Notice

We may update this Privacy Notice periodically to reflect:

·        legal developments;

·        regulatory guidance;

·        operational changes;

·        technological developments.

The latest version will always be available on our website.