Legal
Privacy Policy
Last updated: 29 June 2026
Company No.
15979575
VAT No.
506 7289 75
ICO Ref.
ZC092514
Data Protection Contact
Ikram Rabbani
Registered Office
Sunnymeade, Bennett Road, Manchester M8 5FA
Who We Are
Imperium Executive Search Limited is an executive search company focused on senior leadership, executive, board-level and specialist appointments across infrastructure, engineering, construction, real estate, energy, utilities, transport and related markets, operating on a retained basis. Imperium Executive Search Limited is registered in England and Wales. Company number: 15979575. VAT number: 506 7289 75. Registered office: Sunnymeade, Bennett Road, Manchester M8 5FA. Data Protection Contact: Ikram Rabbani. Email: [email protected]. ICO registration number: ZC092514. For the purposes of this Privacy Policy, "Imperium", "we", "us" and "our" means Imperium Executive Search Limited.
Purpose of This Privacy Policy
This Privacy Policy explains how we collect, use, store, share and protect personal data in connection with our executive search, recruitment, candidate sourcing, client engagement, business development and website activities. This policy applies to: candidates; prospective candidates identified through executive search or talent mapping; clients and prospective clients; business contacts; referees; suppliers and professional advisers; people who contact us through our website, email, telephone, LinkedIn or other channels; and individuals whose details are provided to us by candidates, clients, referees or other professional contacts. We process personal data in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations and other applicable privacy and data protection laws.
Personal Data We Collect
For candidates and prospective candidates we may collect: name; business and personal contact details; CV, biography or professional profile; current and previous employment details; job title, seniority, responsibilities and reporting lines; qualifications, professional memberships and career history; skills, experience, sector expertise and project experience; remuneration details, salary expectations, benefits, bonus arrangements and notice period; location, mobility, relocation preferences and right-to-work status where relevant; LinkedIn profile or other professional profile information; interview notes, assessment notes, shortlisting comments and client feedback; communications between you and us; records of roles discussed, introductions made and candidate authority to represent you; information provided by referees, clients or other professional contacts; and source information showing where we identified your details. We do not routinely collect special category data. For clients and business contacts we may collect: name; job title; employer or organisation; business email address; business telephone number; LinkedIn or professional profile; hiring requirements; meeting notes; communications history; terms of business, contracts, invoices and payment records; and marketing preferences and opt-out records. When you use our website or contact us online, we may collect: information submitted through contact forms; email address and message content; IP address; browser and device information; website usage information; and cookie and analytics data, where applicable.
How We Collect Personal Data
We may collect personal data: directly from you; from your CV, biography, email, LinkedIn profile or professional profile; from clients, employers, referees or professional contacts; from publicly available sources, including company websites, press releases, Companies House, professional directories, industry publications and event materials; from recruitment platforms, job boards and professional networking platforms; from referrals and recommendations; through our website, email, telephone, meetings, video calls or social media channels; and from our own market mapping and executive search research. Where we obtain your personal data from a third-party or public source, we will provide you with privacy information as soon as reasonably practicable, and normally no later than one month after obtaining your data, unless an exemption applies.
How We Use Personal Data
We use personal data for the following purposes: identifying and approaching potential candidates for executive, senior leadership and specialist roles; assessing candidate suitability, experience, availability and interest; discussing career opportunities with candidates; creating candidate profiles, shortlists and market maps; introducing candidates to clients where appropriate; managing client assignments and recruitment mandates; communicating with clients and prospective clients about executive search and recruitment services; arranging interviews, meetings and candidate discussions; obtaining references or verification information where appropriate; managing contracts, terms of business, invoices and payments; maintaining accurate recruitment and business records; complying with legal, regulatory, tax and accounting obligations; responding to complaints, disputes or legal claims; maintaining security and preventing misuse of our systems; sending relevant business development, market intelligence or recruitment-related communications where lawful; and maintaining opt-out and suppression records.
Lawful Bases for Processing
We only process personal data where we have a lawful basis to do so. We commonly rely on legitimate interests where we process personal data for executive search, recruitment, business development, candidate sourcing, candidate assessment, client relationship management and market mapping. Our legitimate interests include: providing executive search and recruitment services; identifying suitable candidates for senior and specialist roles; supporting clients with leadership hiring and succession planning; helping candidates consider relevant career opportunities; maintaining business relationships with clients and professional contacts; promoting our services to relevant business contacts; and protecting our commercial interests and enforcing our terms of business. Before relying on legitimate interests, we consider whether our interests are overridden by your rights, freedoms and interests. We may also rely on contract where processing is necessary to enter into or perform a contract; legal obligation where required to comply with legal, regulatory, tax, accounting or statutory obligations; consent in limited circumstances where you have specifically opted in; and legal claims where necessary to establish, exercise or defend legal claims.
Candidate Authority and Submission to Clients
We will not knowingly submit an identifiable candidate CV, profile or personal details to a client for a specific role without first taking reasonable steps to confirm that the candidate is aware of the opportunity and has authorised us to represent them for that role or client. Where a client's identity has not yet been disclosed to a candidate, we may share anonymised or non-identifiable candidate information with the client to assess potential suitability. We will limit the candidate information shared with clients to what is relevant and necessary at the relevant stage of the recruitment process.
Special Category Data and Criminal Offence Data
Special category data includes information relating to health, disability, race, ethnicity, religious beliefs, political opinions, trade union membership, sexual orientation, biometric data and genetic data. We do not routinely request or process special category data unless it is necessary and lawful to do so. Where we process special category data, we will identify an appropriate lawful basis and a separate special category condition under data protection law. Criminal offence data will only be processed where necessary, lawful, proportionate and relevant to the role or legal requirements. In most cases, criminal record checks and formal vetting will be carried out by the client or employer, not Imperium, unless otherwise agreed.
References, Verification and Vetting
Where appropriate, we may assist with reference, qualification, professional membership or employment verification. We will only request information that is relevant and necessary. Clients are responsible for carrying out final employment checks, including right-to-work checks, references, qualification checks, medical fitness checks, professional registration checks, criminal record checks and any sector-specific requirements, unless expressly agreed otherwise in writing. Where we identify discrepancies in candidate information, we will take reasonable steps to give the candidate an opportunity to comment or clarify before the information is relied upon.
Business Development and Marketing
We may contact corporate clients, prospective clients and business contacts about our executive search and recruitment services where we believe the communication is relevant to their role or organisation. Where we rely on legitimate interests for business development, we will always provide a clear way to opt out. You can opt out of future business development or marketing communications at any time by replying "Opt out" or "Unsubscribe". We maintain suppression records to ensure that opt-out requests are respected.
Automated Decision-Making and AI
We do not make solely automated recruitment decisions about candidates. We may use technology to assist with administration, research, database management, search activity or communication management. Any recruitment decision involving candidate suitability, progression or submission to a client involves human review. If we introduce any system that carries out automated decision-making or profiling with a significant effect on candidates, we will review our data protection obligations, carry out an appropriate assessment and update this Privacy Policy where required.
Who We Share Personal Data With
We may share personal data with: clients and prospective clients, where relevant to a search assignment or recruitment process; candidates, where relevant to a role or recruitment process; referees and previous employers, where appropriate; professional advisers, including accountants, lawyers and insurers; IT, CRM, email, hosting, cloud storage and website service providers; payment, banking and accounting providers; regulators, law enforcement, courts, tribunals or public authorities where required; and third-party partners involved in an agreed recruitment process, including local employment partners, where necessary and lawful. We require third-party service providers to protect personal data and only use it for authorised purposes.
International Transfers
We work with clients and candidates in the UK and internationally, including the Middle East. Where personal data is transferred outside the UK, we will take steps to ensure that the transfer is lawful and that appropriate safeguards are in place where required. These safeguards may include adequacy regulations, contractual safeguards, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, transfer risk assessments or other lawful transfer mechanisms. Where a client or third-party partner is based outside the UK, candidate data will only be shared where it is necessary, proportionate and lawful for the recruitment process.
Data Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, disclosure, alteration or destruction. These measures may include: password protection; multi-factor authentication where available; restricted access to candidate and client records; secure email and cloud storage; access controls; confidentiality obligations; staff awareness and training; and secure deletion and retention controls. No system can be guaranteed as completely secure. However, we take reasonable steps to protect the personal data we hold.
Data Retention
We do not keep personal data for longer than necessary. Retention periods depend on the nature of the data, the purpose of processing, legal requirements and whether there is an ongoing relationship, assignment, dispute or legal obligation. As a general guide: candidate data for active assignments is retained for the duration of the assignment and for a reasonable period afterwards; candidate data held for future opportunities is normally reviewed at least every 24 months; unsuccessful role-specific candidate data is normally retained for up to 12 months after the recruitment process ends, unless a longer period is justified; client, supplier, contract and invoice records may be retained for up to six years or longer where legally required; opt-out and suppression records may be retained for as long as necessary to ensure we do not contact you again; and vetting, verification or highly sensitive information will be deleted as soon as it is no longer required, unless retention is legally necessary.
Your Rights
Depending on the circumstances, you may have the right to: request access to your personal data; request correction of inaccurate or incomplete personal data; request erasure of your personal data; request restriction of processing; object to processing based on legitimate interests; object to direct marketing; request data portability where applicable; withdraw consent where processing is based on consent; and challenge solely automated decisions, if applicable. These rights are not absolute and may be subject to legal exemptions. To exercise your rights, contact us at [email protected]. We may need to verify your identity before responding to your request.
Complaints
If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve the issue. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at www.ico.org.uk.
Links to Other Websites
Our website may contain links to third-party websites, including LinkedIn or client websites. We are not responsible for the privacy practices, content or security of third-party websites.
Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, legal obligations or recruitment practices. The latest version will be published on our website.
For any privacy-related enquiries, please contact us at [email protected]