Introduction

Barclay Simpson Associates Limited, Barclay Simpson Interim Services Limited, Barclay Simpson Solutions Limited and Barclay Simpson Europe Limited (referred to as Barclay Simpson or we or our or us) are committed to protecting and respecting your privacy. We want to provide a safe and secure user experience.

We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this Privacy Policy.

This Privacy Policy aims to describe how we collect, use and process your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you or if you are visiting our website.

This Privacy Policy applies to the personal data of our:

Candidates: applicants for roles advertised or promoted by us (through our website, job boards, social media sites or other sources) as well as people who have supplied a speculative CV to Barclay Simpson not in relation to a specific job. In this Privacy Policy the term Candidate includes individual contractors and individuals supplying their services via personal services and umbrella companies.

Clients and business contacts: our customers, clients and prospective customers and clients to whom we provide or market our recruitment services in the course of our business.

Suppliers: partnerships and companies (including sole traders) contractors and consultants, who provide services to Barclay Simpson. The Supplier will be responsible for communicating this Privacy Policy to their or its employees.

Website Users: any individual who accesses our website.

It does not apply to Barclay Simpson staff and employees who will be issued with separate fair processing information.

For the purposes of the UK GDPR and any other data protection legislation that may be applicable, Barclay Simpson is the data controller and is responsible for your personal data.

Our nominated Data Protection Representative (DPR) is Ian Coyle and the DPR’s contact details can be found at the end of this Privacy Policy.

What kind of information do we collect?

Candidate Data

Depending on the circumstances, we may collect some or all of the information listed below to enable us to offer you employment opportunities tailored to your circumstances and interests. This may include: your name, contact numbers, email addresses, curriculum vitae, photograph, education details, employment history, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website) immigration status, financial information (where we need it to carry out financial background checks or pay you), social security number and tax-related information, referee details, details about your current remuneration, pensions and benefits arrangements and emergency contact details. In addition, you may choose to share other information with us that you think is relevant.

Where appropriate or necessary (and in accordance with legal requirements) we may also collect information related to your health or details of any criminal convictions (where this is required for a role that you are applying for). We may ask you to provide diversity information (on a voluntary basis) for the reasons and in the circumstances set out below.

Finally, the building in which our office is located has CCTV installed in the ground floor reception and common areas and therefore if you visit us at our premises we may collect CCTV footage.

Client Data

We collect your personal data (such as name and contact details) when we receive it directly from you such as where you contact us proactively (by phone, email, in person) or where you connect with our consultants on business networking sites or through our consultant’s business development activities more generally.

We may seek more information about you from analysing online and offline media and we may be supplied with information about you by Candidates (for example when you are named as a referee).

We may also collect or derive limited professional information about business contacts, including job title, employer, business contact details and likely responsibility for recruitment.

Supplier Data

We need a small amount of personal data to ensure our relationship with you runs smoothly such as contact details of relevant individuals at your organization so that we can communicate with you and we may need bank details so that we can pay you for the services you provide.

How do we collect personal data?

We collect information about Candidates when you register as a Candidate with Barclay Simpson by completing the registration form on our website (www.barclaysimpson.com) or by sending us your CV or by corresponding with our consultants by phone, e-mail or in person.

You may also provide us with your personal data when you use our website, subscribe to our services, participate in salary and other market surveys, attend our events, participate in discussion boards or other social media functions on our site, apply for jobs with us via a job board which then redirects you to our website and if you report a problem with our website.

We may also receive personal data about you from other sources such as referees, our Clients and from third party sources, such as LinkedIn and other job board websites, your business card and personal recommendations. For example, if you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites and if you were referred to us through a recruitment process outsourcer (RPO) or other Supplier – they may share personal information about you with us.

Where we obtain your information through LinkedIn or other business networking sites (for example where you choose to connect with one of our consultants) you will be able to access this Privacy Policy so that you can review it and decide what information you would like us to provide to you.

We also work closely with third parties including our group companies, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

For business development, we may use publicly available vacancy and professional information, corporate websites and reputable business information services to identify relevant corporate organisations and business contacts. We may infer likely business contact details or responsibilities and take reasonable steps to check accuracy. Where we obtain information from another source, we will link to this policy in our first communication.

We may also receive limited information from Clients about the progress and outcome of a Candidate’s application, assessment or engagement. We use this information to manage the recruitment process, maintain accurate records, meet legal and regulatory obligations and administer contractual and fee arrangements.

What information do we collect about website users?

When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content.

We will also collect data from you automatically via cookies in line with the cookie settings in your browser. If you would like to know more about cookies including how we use them and the choices available please refer to the Cookies section of this Privacy Policy.

How do we use your personal data and what is the legal basis for the processing?

We use Candidate data as follows:

Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment services.

Providing you with our recruitment services and to facilitate the recruitment process. Assessing data about you against vacancies which we think may be suitable for you.

Sending your information to Clients (with your prior consent) in order to apply for jobs or to assess your eligibility for jobs.

Where we introduce you to a Client in relation to a particular opportunity, the Client will normally process your personal data as a separate data controller for its own assessment, selection, contracting, onboarding and engagement purposes. We will tell you the Client’s identity and obtain your prior consent before sending your information. The Client is responsible for providing information about its subsequent processing.

Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you.

Carrying out our obligations arising from any contracts entered into between us.

Carrying out our obligations arising from any contracts entered into between Barclay Simpson and third parties in relation to your recruitment.

Facilitating our payroll and invoicing processes (when Barclay Simpson is responsible for paying you). Carrying out market surveys and market reports.

Verifying details you have provided, using third party resources (such as psychometric evaluations and regulatory checks).

To request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and necessary with respect to roles you are applying for).

Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties.

To establish, exercise or defend legal claims.

Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you such as, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices.

We use Client data as follows:

To provide our Clients with the best service possible.

We may use Client Data to identify and contact relevant business people at corporate organisations that may require recruitment services, including in relation to publicly advertised vacancies.

We may store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements on our database.

From time to time, we may also ask you to undertake a customer satisfaction survey.

To establish, exercise or defend legal claims.

Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you such as, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices.

We use Supplier data as follows:

To facilitate receipt of services from you and we hold your financial data so that we can pay you for your services.

To establish, exercise or defend legal claims.

To enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

Legal Grounds for Processing your Personal data

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organization or any other contract to provide services to you or receive services from you or your organization.

We will rely on legal obligation if we are legally required to hold information on you to fulfill our legal obligations – including where you are applying for roles or are placed in a role in a regulated environment.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce a Candidate to a Client and in relation to sending third party marketing communications to you via email. To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

Please contact us on dataprotection@barclaysimpson.com if you would like to withdraw your consent.

Where we need to collect personal data by law or under a contract, and you fail to provide it when requested, we may not be able to perform the contract or service. We will notify you if this is the case.

Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data are described below:

We rely on legitimate interests under data protection law for proportionate business-to-business marketing directed to corporate subscribers. Each email identifies Barclay Simpson and the individual sender and includes an unsubscribe link. We respect all objections and opt-outs.

In order to support our Candidates’ career aspirations and our Clients’ resourcing needs we require a database of Candidate and Client personal data containing historical information as well as current resourcing requirements.

As a recruitment business and recruitment agency we introduce Candidates to Clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our Candidates and our Client contacts is a fundamental, essential part of this process.

We think that it is reasonable to expect that if you are looking for employment or have posted your professional background and information on a job board or professional networking site which allows recruiters to view it, you are happy for us to use it to offer recruitment services, assess your skills and, with your consent, share it with prospective employers.

Once an offer of a role is made to a Candidate, your prospective employer may also want to double check information you have given us, such as psychometric results, references, qualifications and criminal-record information, to the extent appropriate and necessary for the role.

Consent

Should we need to rely on consent, we will request it orally, by email or online for the specific activity and record your response. You may withdraw consent to that processing at any time.

Establishing or defending legal claims

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local law, special category personal data in connection with exercising or defending legal claims.

This may arise where we need legal advice or must preserve or disclose information as part of legal proceedings.

Equal opportunities monitoring

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities.

We may ask you to provide information about ethnic background, gender, disability, age, sexual orientation, religion or similar beliefs so we can use it on an anonymised basis to monitor our equal-opportunities policy.

We may disclose anonymised data to Clients where contractually required or requested for their own diversity goals and employment processes.

You will be asked to explicitly agree to us collecting and using this information. You may withdraw your consent, unless another lawful reason justifies continued processing, in which case we will tell you.

Change of purpose

We will use personal data for the purposes for which it was collected unless a new purpose is compatible. Contact dataprotection@barclaysimpson.com for an explanation. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis.

We may process personal data without your knowledge or consent where required or permitted by law.

Automated Decision Making or Profiling

Barclay Simpson does not make decisions about Candidates based solely on automated processing where those decisions produce legal or similarly significant effects. Our systems may search, organise and compare information using criteria selected by our staff, but a person remains involved in Barclay Simpson’s recruitment decisions.

Before a communication is sent, automated tools may assist us to collect, derive, match or prioritise business information, but a person decides whether and how to contact you.

A Client may operate its own testing, scoring or assessment process as a separate data controller. Where we know that such a process applies, we will direct you to the Client’s privacy information and provide relevant information before you participate.

Sharing your personal data

Group Companies

We may share with or give access to your personal data to other companies within the Barclay Simpson Group. An appropriate level of data protection is ensured for this transfer on the basis of the company’s intragroup agreement and SCCs as described below.

Group sharing may support central services such as payroll, IT, commercial and sales support; global, regional or senior executive searches; key accounts; and positions that can be fulfilled remotely.

The applicable lawful basis is performance of a contract or steps to enter into a contract, and Barclay Simpson’s legitimate interests in delivering its services using internal resources.

If you register as a Candidate in a different country from the one in which you first joined Barclay Simpson, a unique record may be created to avoid duplication and improve accuracy. The relevant Group companies share information as independent data controllers.

Third Parties

We may use contracted service providers to support business-information research, data verification, hosting, customer relationship management and the sending of business-to-business communications. They process personal data for us subject to appropriate contractual and security controls.

We may disclose Candidate Data to Clients and prospective Clients to whom we introduce you in relation to a particular opportunity. Those organisations will normally act as separate data controllers. We disclose only information reasonably required for the opportunity.

We do not ordinarily provide special-category or criminal-offence information, identity documents, tax identifiers, bank details or payment credentials unless this is necessary, lawful and explained to you in advance.

In addition, we may disclose your personal data if legally required; to law enforcement, regulators or government officials; and to new business owners and advisers following a reorganisation, merger, sale or other transfer of our business.

International transfers

Some Barclay Simpson Group companies, service providers and Clients are located outside the UK. Where we transfer personal data to a recipient in another country, we comply with applicable international-transfer requirements.

Where the recipient is not covered by UK adequacy regulations, we use an appropriate safeguard where required, such as the UK International Data Transfer Agreement or the European Commission Standard Contractual Clauses together with the ICO UK Addendum. We also complete any required data protection test.

You may request information about the safeguard applying to a particular transfer by contacting dataprotection@barclaysimpson.com. Where a Client receives your personal data as a separate controller, that Client may use systems and service providers in other countries in accordance with its own privacy information and legal obligations.

Data Security

It is important to be aware that transmission over the internet is not completely secure. Although we do our best to protect personal data, we cannot guarantee the security of data transmitted to our website; transmission is at your own risk. Once received, we use procedures and security features to try to prevent unauthorised access.

Personal data held by Barclay Simpson is stored on or accessed through appropriately secured business systems. Some Group companies, service providers and Clients may access or process personal data outside the UK, as explained in the “International transfers” section above.

We have put in place appropriate security measures to prevent personal data being accidentally lost, used, accessed, altered or disclosed without authorisation. Access is limited to people with a business need to know who are subject to appropriate duties.

We have procedures to deal with suspected personal data breaches and will notify you and any regulator where legally required.

Retention of your data

We retain personal data only as long as necessary for our legitimate interests and the purposes for which it was collected, including legal, accounting and reporting requirements.

We consider the amount, nature and sensitivity of the data, the potential risk of harm, the purposes of processing, alternative means and applicable legal requirements when setting retention periods.

We may archive data or retain it only on financial systems, delete it from our main CRM, or pseudonymise parts to ensure suppressed or deleted information is not re-entered unless requested.

Pseudonymised Data replaces identifying fields with artificial identifiers or pseudonyms.

Details of retention periods are available in our retention policy, which you can request from dataprotection@barclaysimpson.com.

If you object or unsubscribe, we will stop using your personal data for direct marketing. We may retain limited contact details on a suppression list so that we can respect your choice.

This section describes Barclay Simpson’s retention of your personal data. A Client receiving your information as a separate controller will determine its own retention periods and should explain them in its privacy information.

Your legal rights

Under the UK and EU GDPR, you have the right to:

Request access to your personal information, including confirmation of whether we process it, relevant categories, purposes and recipients, subject to the rights and interests of others.

Request correction of incomplete or inaccurate personal information.

Request erasure where there is no good reason for continued processing, including after a valid objection.

Object to processing based on legitimate interests because of your particular situation, and object to direct marketing. Contact dataprotection@barclaysimpson.com to change marketing preferences.

Request restriction of processing, for example while accuracy or the reason for processing is established.

Request transfer of your personal information to another party in certain formats, where practicable.

Withdraw consent at any time where processing relies on consent. This does not affect earlier lawful processing and may affect our ability to provide certain services.

If you wish to exercise any right, contact the DPR at dataprotection@barclaysimpson.com.

Where personal data has been provided to a Client acting as a separate controller, you may also exercise your rights directly with that Client. Barclay Simpson will provide the relevant contact details or reasonably assist in directing your request.

There is normally no fee, although a reasonable fee may be charged or a request refused if it is clearly unfounded, repetitive or excessive.

We may request information to confirm your identity and may ask for further information to help us respond.

We aim to respond within one month. We will tell you and keep you updated if a complex or multiple request requires longer.

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to:

 

Ian Coyle, Privacy Lead

Barclay Simpson Associates Limited

dataprotection@barclaysimpson.com

3 New Street Square, London EC4A 3FB

+44 (0) 207 936 2601

EU Representative

Instant EU GDPR Representative Ltd – Adam Brogden

contact@gdprlocal.com | +353 15 549 700

INSTANT EU GDPR REPRESENTATIVE LTD, 69 Esker Woods Drive, Lucan, Co. Dublin, Ireland

You have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority. We would appreciate the opportunity to address your concerns first.

 

Approved by the Board of Directors

Ian Coyle, Chairman

2 September 2026