Business Development & Professional Contacts Privacy Notice

1.      Purpose of this notice

This notice explains how we process personal data relating to individuals we contact for:

·        Business development

·        Recruitment partnership and client acquisition

·        Professional networking and outreach

·        Sales and marketing communications in a B2B context

2. What personal data we process

We may process:

·        Name

·        Job title

·        Employer and business affiliation

·        Work contact details (email address and/or telephone number)

·        Professional profile information (e.g. LinkedIn or company website information)

·        Interaction history (calls, emails, meeting notes, and CRM records)

We do not intentionally process personal data relating to individuals in a purely personal capacity.

3. Sources of personal data

We obtain business contact data from the following categories of sources:

·        Publicly available professional and business sources (including company websites and professional networking platforms)

·        Licensed third-party data providers and business information services

·        Data enrichment and verification services used to improve accuracy of professional contact information

·        Existing client and professional relationships and referrals

Where third-party data providers or enrichment services are used, they may aggregate or verify information from multiple lawful sources, including publicly available and licensed datasets.

We do not rely on any single exclusive data source for business contact information.

4. Lawful basis – Legitimate Interests

We process business contact data under Article 6(1)(f) UK GDPR (legitimate interests).

Our legitimate interests include:

·        Developing and maintaining business relationships with organisations

·        Identifying relevant hiring and recruitment opportunities

·        Providing recruitment services to commercial clients

·        Expanding and improving our professional network

We carry out a balancing test (Legitimate Interests Assessment) to ensure that our interests are not overridden by the rights and freedoms of individuals. This assessment considers:

·        The professional nature of the data processed

·        Reasonable expectations of contact in a business-to-business context

·        Transparency of data sourcing and processing

·        Availability of opt-out mechanisms and suppression lists

·        The limited and non-intrusive nature of the processing

5. PECR compliance

We comply with the Privacy and Electronic Communications Regulations (PECR), including:

·        Screening telephone numbers against the Telephone Preference Service (TPS) and Corporate Telephone Preference Service (CTPS) where applicable before making marketing or business development calls

·        Ensuring that individuals and businesses who have opted out of marketing communications are not contacted

·        Including clear opt-out and unsubscribe mechanisms in all marketing communications

·        Maintaining internal suppression lists to prevent further contact where objections are received

Where a telephone number is listed on TPS or CTPS, it will not be used for unsolicited marketing or business development calls unless a lawful exemption applies.

6. Article 14 transparency

Where we obtain personal data indirectly, we will provide individuals with the following information:

·        Our identity and contact details

·        The purposes and lawful basis of processing

·        Categories of personal data processed

·        The source or category of source of the data (where applicable)

·        Retention periods

·        Rights of the individual, including the right to object to processing and direct marketing

This information may be provided:

·        at the point of first contact, or

·        within one month of obtaining the data, where earlier provision is not reasonably practicable

7. Data enrichment and verification

We may use third-party services to enrich and verify business contact data in order to ensure accuracy and relevance.

These services are used to:

·        Improve accuracy of professional contact information

·        Reduce outdated or incorrect records

·        Support legitimate business development activities

We require all such providers to process data lawfully and to implement appropriate security and contractual safeguards.

8. Suppression and objections

Individuals have the right to object at any time to:

·        Business development communications

·        Telephone contact

·        Email marketing

Where an objection is received, we will:

·        Record the objection in our suppression system

·        Prevent further marketing or business development contact

·        Retain minimal necessary data solely to ensure the suppression request is respected

9. Retention

We retain business contact data only for as long as it remains relevant for legitimate business development purposes. Data is reviewed periodically and removed or suppressed where no longer required.