Privacy Policy


This privacy policy applies between you, the User of this Website and WithFrontier Limited
(“Withfrontier”), the owner and provider of this Website.

Withfrontier is a recruitment agency and recruitment business. We may introduce candidates to
clients for permanent employment, fixed-term contract and temporary worker placements. The
collection, use and transfer of personal information is a fundamental and an essential part of this
process and we are committed to safeguarding the personal information of our clients,
candidates and others that we work with.

This privacy policy applies to our use of any and all Data collected by us or provided by you in
relation to your use of the Website and through other interactions with you (for example
marketing activities).

This privacy policy should be read alongside, and in addition to, our Terms of Use, which can be
found at [HERE].

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

1. Data

collectively all information that you submit to WithFrontier via
the Website. This definition incorporates, where applicable, the
definitions provided in the Data Protection Laws;

2. Cookies

A small text file placed on your computer by this Website when
you visit certain parts of the Website and/or when you use
certain features of the Website. Details of the cookies used by
this Website are set out in the clause below titled “Cookies”;

3. Data Protection Laws

The relevant national data privacy and data protection laws and
regulations applicable to the Processing of Personal Data, and
in particular, the GDPR, the UK GDPR, as applicable;


The General Data Protection Regulation (EU) 2016/679 on the
protection of individuals with regard to the processing of
personal data;

5. Withfrontier, we or us

Withfrontier Limited, a company organized in England, whose
registered office is at Camburgh House, 27 New Dover Road,
Canterbury, Kent, United Kingdom, CT1 3DN;


As it applies under UK law by virtue of section 3 of the

European Union (Withdrawal) Act 2018;

7. User or you

Any third party that accesses the Website and is not either (i)
employed by WithFrontier and acting in the course of their
employment or (ii) engaged as a consultant or otherwise
providing services to WithFrontier and accessing the Website
in connection with the provision of such services; and

8. Website

The website that you are currently using, https://withfrontier.com/, and any sub-domains of this
site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:
1. the singular includes the plural and vice versa;
2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses,
clauses, schedules or appendices of this privacy policy;
3. a reference to a person includes firms, companies, government entities, trusts
and partnerships;
4. “including” is understood to mean “including without limitation”;
5. reference to any statutory provision includes any modification or amendment of it;
6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of WithFrontier and Users with respect to
this Website. It does not extend to any websites that can be accessed from this Website
including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, WithFrontier is the “data
controller”. This means that WithFrontier determines the purposes for which, and the
manner in which, your Data is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you, in each
case, in accordance with this privacy policy:

We collect, store and use your contact details including your name, email address and work and
personal telephone numbers which you provide directly to us.


We collect the following personal information:

 Name, job title, address, telephone number and email address;
 CV which may include your date of birth, education and employment history, your
competencies and skills.
 Third party referee information which will include the name and contact details of your
 Links to your professional profile on business social media, e.g. LinkedIn and other
social media personal information.
 Any other personal information you choose to share with us which may include current
salary, aspirational salary, notice period and from time to time, special or sensitive
personal information.
 Gender when requested by our clients as part of their diversity and inclusion reporting.
 Information captured in any contact forms available on our website.
Special category personal information:
We process the following special category personal information and only with your prior
 Information relating to your health which you choose to share with us and which you feel
is relevant to a role you are interested in. We do not share this information with our
clients however, we will ensure that your need for any workplace adjustments is shared
with our clients.
 Information relating to your race, religion and sexual orientation when requested by our
clients as part of their diversity and inclusion reporting.
Where personal and special category personal information is collected by us for our clients’
diversity and inclusion reporting, we anonymise your response before sharing the information
with our clients.

How we collect Data

6. We collect Data in the following ways:

1. data is given to us by you – for example you send us your CV, or contact us via
our contact form;
2. data is collected automatically; and
3. data from third parties and publicly available sources – for example social media

Data that is given to us by you

7. Withfrontier will collect your Data in a number of ways, for example:
1. when you contact us through the Website, by telephone, post, e-mail or through
any other means;
2. when you complete surveys that we use for research purposes (although you are
not obliged to respond to them);
3. when you elect and consent to receive marketing communications from us;
4. when you use our services; or
5. when you apply for a job with us, or through us,

in each case, in accordance with this privacy policy.

Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for
1. we automatically collect some information about your visit to the Website. This
information helps us to make improvements to Website content and navigation,
and includes your IP address, the date, times and frequency with which you
access the Website and the way you use and interact with its content.
2. we will collect your Data automatically via cookies, in line with the cookie settings
on your browser and your consent. For more information about cookies, and how
we use them on the Website, see the section below, headed “Cookies”.

Data from third parties and publicly available sources
9. We may receive personal data from various third parties as set out below:
1. identity and contact data from other individuals at your organisation
2. information given to us by our clients and businesses that we work with
3. technical data from analytics providers and/or search information providers; and
4. employment, identity and contact data from previous employers, etc.

Our use of Data and the legal basis for processing
1. We use your personal information to provide recruitment services to you on the
basis of our legitimate business interest and in order to perform contracts we
have in place with you.
2. From time to time we may also use your personal information to proactively
promote current candidates to you and arrange discussions relating to your
current recruitment needs, in both cases by email. Please refer to the section
headed “Your rights” below to find information on how to withdraw your consent
to receiving these emails.

1. We use your personal information:
 to provide you with recruitment services in relation to a current role which you
have either applied for or which we consider you would be interested in and
for future roles that are similar to those you have expressed interest in.
 to keep in touch to discuss your career aspirations and ensure you wish to
remain registered with us.
 to address any enquiries you may have or if you have complained to us about
 to send electronic marketing messages. Please refer to the section headed
“Your rights” below to find information on how to withdraw your consent to
receiving these messages.
 to meet our own legal obligations in relation to auditing, financial reporting,
 to defend our legal rights.
 to comply with legal obligations.
2. We process your personal information on the basis of our legitimate business
interest and in order to perform contracts we have in place with you.

12. For the delivery of direct marketing to you via e-mail, we will need your consent, whether
via an opt-in or soft-opt-in:

1. soft opt-in consent is a specific type of consent which applies when you have
previously engaged with us (for example, you contact us to ask us for more
details about a particular product/service, and we are marketing similar
products/services). Under “soft opt-in” consent, we will take your consent as
given unless you opt-out.
2. for other types of e-marketing, we are required to obtain your explicit consent;
that is, you need to take positive and affirmative action when consenting by, for
example, checking a tick box that we’ll provide.
3. if you are not satisfied about our approach to marketing, you have the right to
withdraw consent at any time. To find out how to withdraw your consent, see the
section headed “Your rights” below.

13. We may process your personal data to comply with a legal obligation. For example, to
notify you about changes to our terms or privacy notice; address a complaint; or comply
with a request from a competent authority.

With whom we share Data

14. We may share your Data with the following groups of people for the following reasons:
1. clients and candidates in relation to specific roles;
2. any of our group companies or affiliates – to ensure the proper administration of
our website and business;
3. our employees, agents and/or consultants – to process enquiries from you.
4. professional advisors – to obtain advice from professional advisers;
5. third party service providers who provide services to us which require the
processing of personal data for example IT service providers – to help third party
service providers in receipt of any shared data to perform functions on our behalf
to help ensure the website runs smoothly;
6. other third parties, if we are required to do so by law, or if we believe that such
action is necessary to: (a) fulfil a government, or regulatory authority request; (b)
conform with the requirements of the law or legal process; (c) protect or defend
our legal rights or property, our websites or customers.

When we share your personal information with our clients, we do so on the basis that our clients
are, like us, data controllers. To understand how our clients collect and use your personal
information, please check their privacy policies which are usually available on their websites.
Where we share your information with our suppliers, we do so only where those companies
have appropriate technical and organisational measures in place to ensure the security of your
personal information and any processing they undertake is only carried out on the basis of our

Keeping Data secure

15. We will use technical and organizational measures to safeguard your Data, for example
we store your Data on secure servers with encryption.
16. Technical and organizational measures include measures to deal with any suspected
data breach. If you suspect any misuse or loss or unauthorized access to your Data,
please let us know immediately by contacting us via this e-mail
address: james@withfrontier.com.

17. If you want detailed information from Get Safe Online on how to protect your information
and your computers and devices against fraud, identity theft, viruses and many other
online problems, please visit www.getsafeonline.org. Get Safe Online is supported by
HM Government and leading businesses.

Data retention

18. Unless a longer retention period is required or permitted by law, we will only hold your
Data on our systems for the period necessary to fulfil the purposes outlined in this
privacy policy or until you request that the Data be deleted.
19. Even if we delete your Data, it may persist on backup or archival media for legal, tax or
regulatory purposes.

Your rights

20. You have the following rights in relation to your Data:
1. Right to access – the right to request (i) copies of the information we hold about
you at any time, or (ii) that we modify, update or delete such information. If we
provide you with access to the information we hold about you, we will not charge
you for this, unless your request is “manifestly unfounded or excessive.” Where
we are legally permitted to do so, we may refuse your request. If we refuse your
request, we will tell you the reasons why.
2. Right to correct – the right to have your Data corrected if it is inaccurate or
3. Right to erase – the right to request that we delete or remove your Data from
our systems.
4. Right to restrict our use of your Data – the right to “block” us from using your
Data or limit the way in which we can use it.
5. Right to data portability – the right to request that we move, copy or transfer
your Data.
6. Right to object – the right to object to our use of your Data including where we
use it for our legitimate interests.
7. Rights in relation to automated decision making and profiling – the right not
to be subject to a decision based solely on automated processing (including
profiling) that produces legal effects concerning you, or similarly significantly
affects you.

21. To make enquiries, a complaint, exercise any of your rights set out above, or withdraw
your consent to the processing of your Data (where consent is our legal basis for
processing your Data), please contact us via this e-mail
address: james@withfrontier.com. The revocation of consent is only valid prospectively.
22. If you are not satisfied with the way a complaint you make in relation to your Data is
handled by us, you may be able to refer your complaint to the relevant data protection
authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s
contact details can be found on their website at https://ico.org.uk.
23. It is important that the Data we hold about you is accurate and current. Please keep us
informed if your Data changes during the period for which we hold and process it.

Transfers outside the UK

24. Data which we collect from you may be stored and processed in and transferred to
countries outside of the UK. For example, this could occur if our servers are located in a
country outside the UK or one of our service providers is situated in a country outside
the UK.
25. We will only transfer Data outside the UK or EEA where it is compliant with data
protection legislation and the means of transfer provides adequate safeguards in relation
to your data, e.g. by way of data transfer agreement, incorporating the current standard
contractual clauses adopted by the ICO and/or European Commission as applicable.
26. To ensure that your Data receives an adequate level of protection, we have put in place
appropriate safeguards and procedures with the third parties with whom we share your
Data. This ensures your Data is treated by those third parties in a way that is consistent
with the Data Protection Laws.
27. Unless you do not consent to us using Google Analytics, Google Analytics (Google Inc.
and its affiliates), we may process your data in the course of providing analytical
information to us about the use of our website. These service providers may collect
and/or transfer your data outside of the UK or EEA.

Links to other websites

28. This Website may, from time to time, provide links to other websites. We have no control
over such websites and are not responsible for the content of these websites. This
privacy policy does not extend to your use of such websites. You are advised to read the
privacy policy or statement of other websites prior to using them.


29. What are cookies? We may collect information using “cookies”. Cookies are small text
files that are placed on your computer by websites that you visit. They are widely used in
order to make websites work, or work more efficiently, as well as to provide information
to the owners of the site. We only place necessary cookies when you visit our Website.


30. You may not transfer any of your rights under this privacy policy to any other person. We
may transfer our rights under this privacy policy where we reasonably believe your rights
will not be affected.
31. If any court or competent authority finds that any provision of this privacy policy (or part
of any provision) is invalid, illegal or unenforceable, that provision or part-provision will,
to the extent required, be deemed to be deleted, and the validity and enforceability of the
other provisions of this privacy policy will not be affected.
32. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or
remedy will be deemed a waiver of that, or any other, right or remedy.
33. This Agreement will be governed by and interpreted according to the law of England and
Wales. All disputes arising under the Agreement will be subject to the exclusive
jurisdiction of the English and Welsh courts.

Changes to this privacy policy

34. WithFrontier reserves the right to change this privacy policy as we may deem necessary
from time to time or as may be required by law. Any changes will be immediately posted on the Website and will apply from your first use of the Website following the alterations.
You may contact Withfrontier by email at james@withfrontier.com.