Privacy Policy

1. Who We Are

Bearcroft Holdings Limited is the data controller responsible for your personal data in connection with the Site and our services, unless otherwise stated. Our contact details are set out in Section 13 (Contact Us) below.

2. Personal Data We Collect

The personal data we collect depends on how you interact with us.

2.1 Website Visitors

When you browse the Site, we may automatically collect:

• Device and usage information, such as IP address, browser type, operating system, referring URLs, pages viewed, and time spent on pages;
• Approximate location derived from your IP address;
• Information submitted through contact or enquiry forms, such as your name, email address, phone number, company name, and the content of your message;
• Cookie and tracking data, as described in Section 7 (Cookies and Similar Technologies).

2.2 Candidates

If you apply for a role, register your CV, or are sourced and contacted by our recruitment consultants, we may collect:

• Identity and contact details, such as your name, email address, phone number, and postal address;
• CV and application information, including employment history, education, qualifications, skills, certifications, and references;
• Information provided during screening, interviews, or assessments, including notes taken by our consultants and assessment or test results;
• Right-to-work and background information where relevant to a role and where permitted by law;
• Salary expectations and current or previous remuneration, where voluntarily provided or relevant to a placement;
• Diversity information, such as gender, ethnicity, or other equal opportunities data, where you choose to provide it and where lawful to do so. This may constitute special category data under Data Protection Law, and we only collect it with your explicit consent or another applicable lawful basis;
• Communications between you and Bearcroft, including emails, call notes, and messages.

2.3 Clients and Prospective Clients

If you engage with us as a client or prospective client, we may collect:

• Business contact details, such as your name, job title, company name, work email address, and phone number;
• Information about your hiring needs, projects, and business requirements;
• Records of our communications and meetings, including details shared when booking an introductory call;
• Billing and contractual information necessary to provide our services.

3. How We Collect Personal Data

We collect personal data:

• Directly from you, for example when you submit a CV, complete a contact form, book an introductory call, or correspond with us by phone or email;
• From third parties, including recruitment platforms, professional networking sites (such as LinkedIn), referees, background check providers, and publicly available sources such as professional profiles and company websites;
• From our clients, where they provide us with information about their hiring requirements or about you in connection with a potential placement.

4. How We Use Personal Data

We use personal data for the following purposes:

• To operate, maintain, and improve the Site;
• To respond to enquiries and requests, including booking introductory calls;
• To match Candidates with suitable roles and to provide recruitment, nearshore delivery, and AI systems services to Clients;
• To assess Candidate suitability, including reviewing CVs, conducting screening and reference checks, and facilitating interviews;
• To communicate with Candidates and Clients about opportunities, services, and updates;
• To maintain our candidate and client databases;
• To comply with legal and regulatory obligations, including right-to-work checks where applicable;
• To monitor and analyse equality, diversity, and inclusion data on an aggregated basis, where lawful;
• To protect the security and integrity of our Site and systems;
• For internal record-keeping, business administration, and to enforce our legal rights.

5. Our Legal Basis for Processing

Under Data Protection Law, we rely on one or more of the following legal bases to process your personal data:

• Consent – for example, where you submit your CV to us, sign up to receive communications, or provide diversity information;
• Legitimate interests – for example, to operate our recruitment business, match Candidates to roles, respond to enquiries, and improve our services, provided this is not outweighed by your interests or fundamental rights;
• Performance of a contract – for example, where we are providing services to a Client or facilitating a placement involving you;
• Legal obligation – for example, where we are required to verify right to work or retain records under applicable law.

Where we rely on consent, you may withdraw that consent at any time by contacting us using the details in Section 13.

6. Special Category Data

We generally avoid collecting special category data (such as data about health, race, ethnicity, religion, or sexual orientation) unless it is necessary and lawful to do so – for example, where you voluntarily provide diversity information for equal opportunities monitoring, or where reasonable adjustments are required during a recruitment process. We will only process such data with your explicit consent or where another condition under Data Protection Law applies, and we apply additional safeguards to protect it.

7. Cookies and Similar Technologies

Our Site uses cookies and similar tracking technologies to operate effectively and to understand how visitors use the Site. Cookies are small text files stored on your device.

7.1 Types of Cookies We Use

• Strictly necessary cookies: required for the Site to function, such as enabling secure areas or remembering form inputs.
• Performance and analytics cookies: help us understand how visitors interact with the Site (for example, via tools such as Google Analytics), including pages visited, time on page, and navigation paths, so we can improve the Site.
• Functionality cookies: remember choices you make to provide a more personalised experience.

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings, including blocking or deleting cookies. Please note that disabling certain cookies may affect the functionality of the Site. Where required by law, we will request your consent before placing non-essential cookies and will provide a mechanism to manage your preferences.

8. Sharing Your Personal Data

We may share personal data with:

• Clients and prospective employers, where you are a Candidate, in order to consider you for a role (we will generally seek your consent before disclosing your CV or personal details to a specific Client, except where you have applied directly to a role we are recruiting for);
• Background check and verification providers, where relevant to a placement and permitted by law;
• Professional advisers, such as lawyers, auditors, and insurers, where necessary;
• Regulators and authorities, where required by law or to protect our legal rights;
• A purchaser or successor, in the event of a merger, acquisition, restructuring, or sale of all or part of our business.

We do not sell personal data to third parties.

9. International Transfers

As Bearcroft sources and works with talent and clients across multiple countries, including through our nearshore hubs, personal data may be transferred to, stored in, or processed in countries outside the United Kingdom or European Economic Area. Where this occurs, we take steps to ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the European Commission's Standard Contractual Clauses, or a determination that the destination country provides an adequate level of protection, in each case as recognised under applicable Data Protection Law.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. As a general guide:

• Candidate data is typically retained for as long as you remain an active candidate in our network, and for a reasonable period afterwards in case suitable opportunities arise, unless you ask us to delete it sooner;
• Client data is retained for the duration of our business relationship and for a reasonable period afterwards for record-keeping and legal purposes;
• Website enquiry data is retained for as long as necessary to respond to and follow up on your enquiry.

Where personal data is no longer needed, we will securely delete, anonymise, or aggregate it.

11. Your Rights

Subject to applicable Data Protection Law, you may have the right to:

• Access the personal data we hold about you;
• Request correction of inaccurate or incomplete personal data;
• Request erasure of your personal data in certain circumstances;
• Object to or restrict our processing of your personal data;
• Request a copy of your personal data in a portable format;
• Withdraw consent at any time, where processing is based on consent;
• Lodge a complaint with a supervisory authority, such as the UK Information Commissioner's Office (ICO), or the relevant data protection authority in your country of residence.

To exercise any of these rights, please contact us using the details in Section 13. We may need to verify your identity before responding to a request, and we will respond within the timeframes required by applicable law.

12. Data Security

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. While we take reasonable steps to safeguard your personal data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of your rights, please contact us at:

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Any changes will be posted on this page with an updated “Last updated” date. We encourage you to review this Privacy Policy periodically.