Last updated: 1 October 2026

1. Introduction

ESPSG Limited ("ESPSG", "we", "us" or "our") is a specialist recruitment and executive search consultancy.

We are committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit our website, contact us, engage with our recruitment services, are identified as a potential candidate or business contact, or otherwise interact with us in a professional capacity.

We process personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

2. Who We Are

ESPSG Limited is the data controller responsible for the personal information covered by this Privacy Policy.

ESPSG Limited
Riverside House
3 Place Farm
Wheathampstead
St. Albans
England
AL4 8SB

Email: info@espsg.net
Telephone: 0208 059 5937
Website: www.espsg.net

If you have any questions regarding this Privacy Policy or the way we process your personal information, please contact us using the details above.

3. Personal Information We Collect

The personal information we collect depends upon your relationship with ESPSG.

Candidates and prospective candidates

We may collect:

• Name and contact details.

• Current and previous employment.

• Job title and professional experience.

• Curriculum vitae and career history.

• Academic qualifications and professional memberships.

• Skills, specialisms and areas of expertise.

• Current and previous employers.

• Salary, remuneration and salary expectations.

• Career preferences and aspirations.

• Preferred locations and geographical mobility.

• Notice periods and availability.

• Information provided during telephone calls, meetings and recruitment discussions.

• References and other information relevant to a recruitment process where appropriate.

Clients and prospective clients

We may collect:

• Names and professional contact information.

• Employer and job title.

• Recruitment responsibilities and hiring requirements.

• Business correspondence.

• Meeting and telephone records.

• Information concerning current or prospective recruitment assignments.

• Other information relevant to our professional relationship.

Website visitors

We may collect:

• Information submitted through website forms.

• Email addresses and correspondence.

• IP address and device information.

• Browser and technical information.

• Website usage information.

• Cookie preferences and related information.

We seek to collect only information that is relevant and reasonably necessary for our recruitment and business activities.

4. How We Obtain Personal Information

We may obtain information directly from you when you:

• Submit a CV.

• Apply or express interest in an opportunity.

• Contact ESPSG by telephone or email.

• Contact us through our website.

• Respond to recruitment correspondence.

• Participate in recruitment discussions.

• Become a client or engage our recruitment services.

As an executive search and recruitment business, we may also identify professionals who have not previously contacted ESPSG.

We may therefore obtain relevant professional information from publicly available or professional sources including:

• LinkedIn and other professional networking platforms.

• Apollo and professional contact or business intelligence databases.

• Law firm, company and employer websites.

• Professional directories.

• Publicly available professional biographies.

• Industry publications.

• Professional networking services.

• Referrals and recommendations.

• Other legitimate publicly available sources.

Where personal information has not been obtained directly from you, we will provide appropriate privacy information within the period required by applicable data protection law unless an exemption applies.

5. How We Use Personal Information

We may use personal information for the following purposes.

Recruitment and Executive Search

To identify individuals who may be suitable for employment opportunities, assess professional experience and qualifications, contact potential candidates and discuss relevant career opportunities.

Candidate Representation

To represent candidates during recruitment processes, communicate with prospective employers, arrange interviews, facilitate discussions and assist with employment opportunities.

Client Recruitment Services

To understand recruitment requirements, identify suitable professionals and provide recruitment and executive search services to clients.

Business Development

To identify organisations and professional contacts who may have a legitimate interest in our recruitment services and communicate with them where permitted by law.

Relationship Management

To maintain professional relationships with candidates, clients and other business contacts.

Business Administration

To manage correspondence, maintain appropriate business records, administer our services and comply with legal and regulatory obligations.

Website Operation

To operate and protect our website, respond to enquiries, understand website usage and improve our online services.

6. Lawful Bases for Processing

Under UK GDPR, we must have a lawful basis for processing personal information.

Depending upon the circumstances, we may rely upon:

Legitimate Interests

We may process relevant professional information where necessary for our legitimate interests in operating a recruitment and executive search business.

This can include:

• Identifying professionals who may be suitable for employment opportunities.

• Contacting prospective candidates about relevant opportunities.

• Assessing candidate suitability.

• Maintaining relationships with candidates and clients.

• Identifying prospective clients.

• Developing and operating our recruitment business.

Where we rely upon legitimate interests, we consider whether our interests are outweighed by the individual's rights, interests and reasonable expectations.

Contract

We may process information where necessary to perform a contract with you or take steps at your request before entering into a contract.

Consent

Where consent is the appropriate lawful basis, we will obtain consent before undertaking the relevant processing.

Consent may be withdrawn at any time.

Legal Obligation

We may process personal information where necessary to comply with legal or regulatory obligations.

7. Candidate Confidentiality, Consent and Transparency

ESPSG believes that candidates should remain in control of their personal information and should know where and when they are being represented.

ESPSG Limited will never submit a candidate's CV, disclose their identity or make an identifiable application or introduction to a prospective employer without first obtaining the candidate's permission.

Candidates are kept fully informed regarding applications and introductions made by ESPSG Limited on their behalf. We will tell the candidate which organisation we propose to approach and obtain their authorisation before their CV or other identifiable information is submitted.

We do not operate on the basis that providing ESPSG with a CV gives us unrestricted permission to distribute it to prospective employers. Permission to represent a candidate will be obtained for the relevant opportunity or prospective employer before identifiable candidate information is disclosed.

Our commitment is simple: your CV belongs to you, your career belongs to you, and you should remain informed and in control of where you are represented.

Where a candidate authorises ESPSG to represent them, we will take reasonable steps to keep them updated on material developments relating to that application or introduction, including relevant client feedback and progression through the recruitment process where such information is provided to us.

Candidate information will only be disclosed to those reasonably involved in the relevant recruitment process and only to the extent reasonably necessary.

We treat candidate confidentiality seriously, particularly where an individual may be exploring opportunities while currently employed.

Where appropriate, ESPSG may discuss a candidate's experience with a prospective client on an anonymous or non-identifiable basis before seeking permission to disclose the candidate's identity or CV. No information that reasonably identifies the candidate will be disclosed without their prior authorisation.

8. Professional Sourcing and Apollo

ESPSG uses professional sourcing and business intelligence services, including Apollo, to assist with identifying potentially relevant professional candidates and business contacts.

Information obtained through such services may include an individual's:

• Name.

• Employer.

• Professional position.

• Business email address.

• Professional history.

• Other business or professional information.

We use this information where we believe there is a legitimate professional or recruitment-related reason for contacting the individual.

We do not assume that inclusion within a professional database constitutes consent to receive marketing communications.

Where required, we assess our lawful basis independently and provide individuals with the ability to object to further communications.

9. Direct Marketing and Professional Communications

ESPSG may contact candidates and professional business contacts regarding relevant recruitment opportunities, recruitment services and related professional matters where permitted by applicable law.

Where we rely upon legitimate interests, we will consider whether the communication is relevant and whether the recipient could reasonably expect such contact in a professional context.

Where consent is legally required, we will obtain consent.

You may object to receiving direct marketing from ESPSG at any time.

You can ask us to stop contacting you by replying to the relevant communication or contacting:

info@espsg.net

Where an individual asks us not to contact them, we may retain a minimal suppression record containing sufficient information to ensure that their preference continues to be respected.

10. Special Category Personal Information

Certain categories of personal information receive additional protection under data protection law. These include information relating to health, racial or ethnic origin, religious beliefs, political opinions, trade union membership, biometric information and sexual orientation.

ESPSG does not routinely seek to collect special category information.

Where it is necessary to process such information, we will identify an appropriate lawful basis under Article 6 UK GDPR and an applicable condition under Article 9 UK GDPR.

11. Who We Share Information With

Where appropriate and lawful, personal information may be shared with:

• Prospective employers authorised by a candidate.

• Clients engaging ESPSG for recruitment services.

• Individuals involved in a recruitment process.

• Technology and IT service providers.

• Website and hosting providers.

• Professional advisers.

• Regulatory, governmental or law enforcement authorities where legally required.

Service providers processing information on our behalf are expected to provide appropriate data protection and security safeguards.

We do not sell personal information.

12. International Recruitment and Data Transfers

ESPSG may work with candidates and organisations located outside the United Kingdom.

Some of our technology providers may also process information internationally.

Where personal information is transferred outside the United Kingdom, we will take appropriate steps to ensure that the transfer complies with applicable UK data protection law.

Depending upon the circumstances, safeguards may include:

• UK adequacy regulations.

• The UK International Data Transfer Agreement.

• The UK Addendum to approved Standard Contractual Clauses.

• Other legally recognised transfer mechanisms.

13. Data Retention

ESPSG does not retain personal information indefinitely simply because it may potentially be useful in the future.

Candidate, prospective candidate and recruitment-related information is generally retained for no longer than 12 months where there is no active recruitment process or continuing professional relationship.

Records are periodically reviewed and information that is no longer reasonably required will be deleted or anonymised.

Information may be retained for longer where:

• You have an ongoing relationship with ESPSG.

• You have asked us to continue representing you.

• You have asked us to retain your information for future opportunities.

• There is an active recruitment process.

• We have a legal or regulatory obligation to retain information.

• Information is reasonably required to establish, exercise or defend legal claims.

Where an individual has requested that we stop contacting them, we may retain a minimal suppression record for longer than the normal retention period so that we can continue respecting that request.

14. Data Security

We take appropriate technical and organisational measures designed to protect personal information against:

• Unauthorised access.

• Accidental loss.

• Improper disclosure.

• Alteration.

• Destruction.

• Unlawful processing.

Access to candidate and client information is limited to individuals who reasonably require access for legitimate business purposes.

No internet-based system can be guaranteed to be completely secure, but we take reasonable measures appropriate to the nature of the information we process.

15. Website Cookies

Our website may use cookies and similar technologies for website functionality, security, analytics and other purposes.

Cookies may include:

Essential cookies required for the operation and security of the website.

Functional cookies used to remember visitor preferences.

Analytics cookies used to understand how visitors use our website.

Marketing cookies where applicable.

Where required by law, non-essential cookies will not be placed without the visitor's consent.

Visitors can manage their preferences using the cookie controls available on our website.

16. Third-Party Technology Providers

We use third-party services and technology to operate our business.

These may include:

• Wix for our website and associated website services.

• Apollo for professional sourcing and business intelligence.

• Email and communication services.

• Cloud storage and productivity services.

• Recruitment and customer relationship management systems.

• Professional networking platforms.

Depending upon the service and circumstances, these organisations may process personal information on our behalf or act as independent data controllers.

We periodically review the services we use and take reasonable steps to ensure appropriate privacy and security protections are in place.

17. Your Data Protection Rights

Depending upon the circumstances, UK data protection law provides you with rights including:

• The right of access – to request a copy of personal information we hold about you.

• The right to rectification – to ask us to correct inaccurate or incomplete information.

• The right to erasure – to request deletion of personal information in certain circumstances.

• The right to restriction – to request that processing is restricted in certain circumstances.

• The right to object – to object to certain processing based upon legitimate interests.

• The right to object to direct marketing – you have an absolute right to object to your personal information being used for direct marketing.

• The right to data portability – where applicable, to receive certain information in a structured, commonly used and machine-readable format.

• Rights relating to automated decision-making – where applicable.

• The right to withdraw consent – where processing is based upon consent.

To exercise your rights, please contact:

info@espsg.net

We may need to verify your identity before processing certain requests.

We will respond within the timescales required by applicable data protection legislation.

18. Automated Processing and Artificial Intelligence

ESPSG may use software, artificial intelligence and other technology to assist with research, administration, candidate identification, matching and analysis.

Technology may assist us in identifying relevant professional experience or potential matches between candidates and recruitment opportunities.

However, ESPSG does not rely solely upon automated decision-making to make decisions that produce legal or similarly significant effects upon individuals.

Human judgement remains an important part of our recruitment and executive search processes.

Where our use of automated processing changes materially, we will review our privacy practices and update this Privacy Policy where appropriate.

19. Third-Party Websites

Our website may contain links to third-party websites or professional platforms.

ESPSG is not responsible for the privacy practices of external websites.

We recommend reviewing the privacy information provided by those organisations before providing personal information.

20. Complaints

If you have concerns about the way ESPSG has handled your personal information, we would encourage you to contact us first so that we have the opportunity to investigate and resolve the matter.

You also have the right to complain to the UK's data protection regulator:

Information Commissioner's Office (ICO)

www.ico.org.uk

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, technology, recruitment practices, regulatory guidance or applicable law.

The latest version will be published on our website together with the date it was last updated.

22. Contact Us

For questions about this Privacy Policy, our processing of your personal information or your data protection rights, please contact:

ESPSG Limited

Riverside House
3 Place Farm
Wheathampstead
St. Albans
England
AL4 8SB

Email: info@espsg.net
Telephone: 0208 059 5937
Website: www.espsg.net

Last updated: 1 October 2026