Privacy Policy
Crowell Search Group Ltd – Privacy Policy
At Crowell Search Group, we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws.
1. Who We Are & Regulatory Compliance
Crowell Search Group Ltd is a boutique recruitment firm that provides permanent talent acquisition and contract workforce solutions specialising in the financial, governmental, and professional services sector.
- Data Controller: Crowell Search Group Ltd (Registered Office: 329 Cavendish Rd, London, SW12 0PQ)
- ICO Registration: We are fully registered as a Data Controller with the UK Information Commissioner’s Office (ICO).
- Cyber Security Framework: Our corporate IT systems, secure cloud environments, and communication networks are officially certified under the UK Government-backed Cyber Essentials scheme.
- Compliance Contact: lucy@crowellsearchgroup.com
2. What Personal Data We Collect
We may collect, store, and process the following categories of personal data:
- Identification & Contact Details: Full name, home address, personal email address, and phone numbers.
- Professional & Employment Data: CVs/resumes, employment histories, academic qualifications, professional certifications, and reference details.
- Financial & Compliance Data (For Contractors): Bank account details, national insurance numbers, right-to-work documentation (passports/visas), payroll preferences, and day-rate histories.
- Vetting Records: Necessary pre-employment screening data, reference verifications, and regulatory or criminal background checks required for financial services placements.
3. How We Use Your Personal Data
We use your personal data strictly to deliver our core professional solutions:
- Executing targeted executive search, permanent placement campaigns, and contracting/interim workforce assignments.
- Matching qualified candidate profiles against open client vacancies and project briefs.
- Managing ongoing placement compliance, timesheet processing, financial invoices, and contractor payroll administration.
- Assessing candidate alignment via manual, qualitative competency interviewing and background validation.
- Navigating and fulfilling statutory legal, taxation (HMRC), and regulatory reporting obligations.
4. Legal Basis for Processing
We process your personal data under one or more of the following compliant UK GDPR lawful bases:
- Legitimate Interests: To run our recruitment business, map market talent, and proactively introduce highly specialised professionals to prospective employers.
- Contractual Necessity: To take steps to evaluate or execute an employment engagement or service contract with you or our clients.
- Legal Obligation: To verify right-to-work status, conduct financial compliance monitoring, or process corporate taxes.
- Consent: Where you explicitly agree to have your data processed for a specific, ongoing talent pipeline assignment.
5. Data Sharing & Logical Separation
We protect your data from cross-contamination. Candidate pipelines and data stored on behalf of specific clients are logically separated inside our secure database.
We only share personal data with:
- Direct corporate clients or designated recruitment process outsourcing (RPO) partners (such as AMS) following qualitative human assessment and alignment confirmation.
- Enterprise cloud infrastructure sub-processors (such as Microsoft 365 / Azure and AWS) hosting our highly secure business productivity suites.
- Regulatory frameworks, auditing bodies, or law enforcement entities where contractually or statutorily mandated by UK law.
6. International Transfers
Our core data storage infrastructure is physically localised within the United Kingdom. If cloud processing applications temporarily transfer personal data outside the UK/EEA, we guarantee equivalent protection by enforcing standard contractual clauses (SCCs) and binding corporate rules compliant with UK GDPR.
7. Data Retention & Secure Disposal
We retain personal data only for as long as required to satisfy the operational objectives of its collection:
- Candidate Files (Permanent Sourcing): Maintained for 2 to 3 years from your last active, meaningful engagement, or until consent is rescinded.
- Placement & Financial Records (Contractors): Retained securely for 6 to 7 years post-contract termination to comply with statutory UK HMRC audit laws.
- Data passing these validation thresholds is permanently and securely purged from our underlying cloud servers using certified digital destruction protocols.
8. Your Rights
Under the UK GDPR, you have the following enforceable statutory rights:
- The right to access your personal data via a Subject Access Request (SAR).
- The right to request the rectification or complete erasure (deletion) of your files.
- The right to object to, or request the restriction of, your data processing.
- The right to data portability.
- The right to withdraw consent at any time without impacting prior lawful processing.
To exercise your data protection rights or submit an inquiry, please contact our founder directly at lucy@crowellsearchgroup.com.
If you remain unsatisfied with our handling, you maintain a statutory right to lodge a formal complaint with the Information Commissioner’s Office (ICO).
9. Cookies and Tracking
Our public website uses localised functional cookies and fundamental tracking mechanisms strictly to maximise website performance and security. We do not deploy invasive third-party analytics or behavioural advertising cookies. Because our site relies exclusively on these essential technical cookies to function properly, a separate cookie management panel is not required, and your continued use of our site constitutes acceptance of these operational tools.
10. Changes to This Privacy Policy
We reserve the right to modify this statement. The most current version will always remain permanently visible on this digital portal.
Crowell Search Group
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