Who we are and what this notice covers

This privacy notice explains how The Holgate Partnership Ltd (“we”, “us”) collects and uses personal data about candidates, people we may approach about roles, referees, client contacts and visitors to our website. We are the controller of this data, which means we decide how and why it is used. We are registered with the Information Commissioner’s Office (ICO) under registration number Z278159X.

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Holgate Partnership Ltd will collect your personal data (which may include special categories of personal data) and will process your personal data for the purposes of providing you with work-finding services, including retained executive search. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, and developing and managing our services and relationship with you and our clients. As a retained executive search firm, we also identify and approach people who have not applied to us, using professional information they have made public (for example on LinkedIn).

If you have opted-in we may also send you marketing information and news via email/text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

The legal bases we rely upon to offer these services to you are:

• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation to which we are subject
• To fulfil a contractual obligation that we have with you

We rely mainly on our legitimate interests for our search work, and on your consent for marketing emails and texts. Where we process special category data, such as health information, we do so only with your explicit consent or where we need to meet our obligations under employment law, for example to make reasonable adjustments.

b. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where The Holgate Partnership Ltd has relied on a legitimate interest to process your personal data, our legitimate interests are as follows:

• Managing our database and keeping work-seeker records up to date;
• Providing work finding services to both candidates and clients;
• Contacting you to seek your consent where we need it;
• Giving you information about similar services to those that you will have used from us recently;
• Identifying and approaching potential candidates for roles we have been retained to fill, using information they have made publicly available;
• Keeping in touch with client contacts and managing our relationships with their organisations;
• Keeping accurate records of our conversations, including call recordings and notes.

c. Statutory/contractual requirements

The Holgate Partnership Ltd has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements). Our clients may require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect in order to comply with our statutory and legal requirements, we may not be able to continue to provide work-finding services to you.

d. Recipients of data

The Holgate Partnership Ltd will share your personal data, including special category data where relevant, with the following recipients:

• Our clients, only when your details are relevant to a specific assignment (including through our secure client portal);
• Your former employers who we may seek references from;
• Psychometric/skills testing providers, as required for certain roles;
• The Company’s accountant for the purposes of financial accounting;
• The Company’s recruitment software provider, which hosts our candidate database and client portal;
• Our call-recording and note-taking provider;
• Data-enrichment providers, who help us keep job titles and work contact details up to date;
• Our IT, email and document storage providers (for example Microsoft 365);
• Our e-signature provider, where you sign documents with us electronically;
• Our professional advisers (such as lawyers and insurers), and regulators, HMRC or law enforcement bodies where the law requires it.

e. Categories of data

The Holgate Partnership Ltd collects the following personal data:

• Name, address, mobile number and email address
• Work and education history, including your CV and LinkedIn profile
• Current job title and employer, salary, bonus and benefits, notice period, and your preferences on location and working arrangements
• Notes and recordings of our conversations with you, and interview feedback from our clients
• References
• Nationality (through right to work check)
• For client contacts: your name, job title, employer and business contact details

Special categories of personal data:

• Health information including whether you have a disability (if you require reasonable adjustments to be made in respect of an application for a role).

f. Where we get your data

We collect personal data:

• Directly from you, for example in your CV, by email or in our conversations;
• From public professional sources, such as LinkedIn, company websites and industry publications;
• From people who recommend you to us, and from referees;
• From data-enrichment providers, who supply current job titles and work contact details;
• From our clients, for example interview feedback.

Where we obtain your data from someone other than you, we will tell you within one month, or when we first contact you if that is sooner.

2. Overseas Transfers

Our main systems are based in the UK and the European Economic Area (EEA). Some of our service providers may process data in other countries, and we may send your details to a client outside the UK when an assignment requires it. When we transfer personal data outside the UK, we make sure it is protected: either the UK Government has confirmed that the country provides adequate protection, or we use the ICO’s International Data Transfer Agreement or Addendum.

3. Data retention

The Holgate Partnership Ltd will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We are required to keep your records relating to the right to work in the UK 2 years after employment or the engagement has ended.

Where The Holgate Partnership Ltd has obtained your consent to process your personal/special categories of personal data, we will do so in line with our retention policy. Upon expiry of that period The Holgate Partnership Ltd will seek further consent from you. Where consent is not granted The Holgate Partnership Ltd will cease to process your personal data/special category data. Where we rely on legitimate interests rather than consent, you can ask us to delete your data at any time.

4. Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to The Holgate Partnership Ltd processing your personal/special category data you have the right to withdraw that consent at any time by contacting Marie Heddle on 020 7702 0200 (marie@holgatepartnership.com). Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

5. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Matthew Waters on 020 7702 0200 (matthew@holgatepartnership.com).

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to. We would, however, appreciate the chance to deal with your concerns first, so please contact us before you approach the ICO.

6. Our website

When you use our website contact form, we use the details you give us to reply to your enquiry. Our website uses cookies.

7. Changes to this notice

We may update this notice from time to time. The latest version will always be on this page.

This website is owned and operated by The Holgate Partnership Ltd.

We are registered in England and Wales under registration number 07440848, and our registered office is at Cumberland House, 24-28 Baxter Avenue, Southend On Sea, Essex SS2 6HZ.

Our principal place of business is at 34 Lime Street, London, EC3M 7AT.

You can contact us:

• By post, to 34 Lime Street, London, EC3M 7AT;
• Using our website contact form;
• By telephone, on 020 7702 0200.

Data protection contact

Our data protection contact’s contact details are: Matthew Waters, 020 7702 0200, matthew@holgatepartnership.com.

Last updated: November 2026
Version: 1