DEFINING IMPACT
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© 2026 Defining Impact · Privacy Policy
Privacy Policy
Last updated: August 20261. Who we areDefining Impact is an executive search and recruitment business connecting senior and specialist professionals with organisations in the UK and internationally.For the purposes of UK data protection law, Harvey Clear trading as Defining Impact is the data controller of the personal information described in this Privacy Policy.Email: [email protected]2. Who this policy applies toThis policy applies to personal information we process about:• candidates and prospective candidates;
• clients and prospective clients;
• hiring managers and other professional contacts;
• referees and individuals who recommend or introduce people to us; and
• visitors to our website.3. Information we collectDepending on our relationship with you, we may collect information including:Candidate information: your name, contact details, CV, LinkedIn or other professional profiles, employment and career history, education, qualifications, skills, responsibilities, achievements, current or previous employers, compensation information, location, willingness to relocate or travel, career preferences and availability.We may also keep records of our communications with you, opportunities and organisations discussed, introductions, applications, interviews, feedback, offers, placements and notes relevant to our professional relationship.Client and business contact information: your name, job title, employer, professional contact details, hiring requirements, correspondence, searches and assignments, previous introductions or placements and other information relevant to our business relationship.Website and communications information: information you provide when contacting us and limited technical information generated through your use of our website.4. Where we obtain informationWe may obtain personal information directly from you or from other sources, including:• LinkedIn and other professional platforms;
• publicly available websites and professional information;
• our existing professional networks and records;
• referrals and recommendations;
• clients, candidates and other professional contacts;
• CVs and information provided to us; and
• recruitment databases, research tools and other professional information services.Executive search involves proactively identifying people who may be relevant to opportunities. We may therefore hold professional information about you before we have spoken to you.5. How we use personal informationWe may use personal information to:• identify people who may be suitable for opportunities;
• contact prospective candidates;
• assess experience and suitability;
• discuss career opportunities;
• identify and introduce relevant candidates to clients and prospective employers;
• manage searches, applications and interview processes;
• communicate feedback and offers;
• make and manage placements;
• maintain relationships with candidates for future opportunities;
• understand and respond to clients' hiring requirements;
• identify and contact prospective clients;
• provide and market our executive search and recruitment services;
• maintain records of conversations, introductions and previous work;
• obtain references or assist with appropriate pre-employment checks;
• administer and improve our business and services;
• establish, exercise or defend legal claims; and
• comply with legal and regulatory requirements.6. Introductions to prospective employersAn important part of our service is connecting people and organisations where we believe there may be a relevant professional opportunity.We may share relevant professional information about candidates with clients or prospective employers where we reasonably believe this is appropriate in connection with our recruitment and executive search services.This may include information contained in a CV, professional profile or information provided to us during our communications.Where appropriate, we will discuss specific opportunities with candidates before making an introduction.We do not sell or rent candidate information, CVs or our candidate database.7. Our lawful basesDepending on the circumstances, we process personal information on one or more of the following lawful bases:Legitimate interests: including identifying and approaching suitable candidates, providing recruitment and executive search services, maintaining professional relationships, developing our business, communicating with business contacts and maintaining appropriate business records.When relying on legitimate interests, we consider whether our interests are proportionate and whether your interests, rights or freedoms override them.Contract: where processing is necessary to enter into or perform a contract with you.Legal obligation: where we are required to process information to comply with applicable law.Consent: where consent is appropriate or legally required. Where we rely on consent, you may withdraw it at any time.8. Sensitive informationWe do not ordinarily seek to collect sensitive or “special category” personal information.However, you may choose to provide information concerning matters such as health, disability, racial or ethnic origin, religious beliefs or other sensitive circumstances, for example where relevant to an interview or recruitment process.Where we process special category personal information, we will only do so where an appropriate lawful basis and additional legal condition applies.Information concerning criminal convictions or offences will only be processed where permitted by law and where genuinely necessary.9. Calls, meetings and AI-assisted notesTelephone calls or video meetings may sometimes be recorded for legitimate purposes such as training, quality assurance or maintaining accurate records. Where we record a call or meeting, we will provide appropriate notice.We may also use technology, including artificial intelligence-enabled tools, to transcribe, summarise or assist us in taking notes during or following conversations.These tools may process personal information on our behalf. Where we use third-party providers, we take reasonable steps to ensure appropriate data protection arrangements are in place.We do not intend to rely solely on automated decision-making to make significant recruitment decisions about candidates.10. Who we share information withWhere appropriate, personal information may be shared with:• clients and prospective employers;
• service providers supporting our business, such as CRM, email, communications, cloud storage, recruitment and IT providers;
• professional advisers;
• reference, verification or background-screening providers where appropriate;
• regulators, courts, law-enforcement agencies or other authorities where legally required; and
• other parties where necessary to establish, exercise or defend legal rights.We only share information where we consider there is an appropriate reason to do so.11. International transfersDefining Impact operates internationally. Personal information may therefore be shared with clients, candidates or service providers outside the United Kingdom.Where UK data protection law requires safeguards for an international transfer, we will use an appropriate lawful transfer mechanism.12. How long we keep informationExecutive search relationships can remain professionally relevant for many years.We retain personal information for as long as we reasonably consider necessary for recruitment, executive search, professional relationship management, business record, contractual or legal purposes.We periodically review the information we hold and may delete or anonymise information that is no longer reasonably required.13. Direct marketing and professional outreachWe may contact candidates about relevant career opportunities and professional matters.We may also contact existing and prospective clients about our executive search and recruitment services where permitted by law.You can ask us to stop using your personal information for direct marketing at any time. We may retain limited information on a suppression list where necessary to ensure that your preference is respected.14. Your rightsDepending on the circumstances, UK data protection law may give you rights to:• request access to your personal information;
• ask us to correct inaccurate information;
• ask us to erase certain information;
• ask us to restrict certain processing;
• object to certain processing, including direct marketing;
• receive certain information in a portable format;
• withdraw consent where we rely upon consent; and
• complain to the Information Commissioner's Office (ICO).These rights are subject to applicable legal conditions and exemptions.To exercise your rights, contact [email protected].You also have the right to complain to the UK Information Commissioner's Office.15. SecurityWe take reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.Access to personal information is restricted where appropriate to people and service providers who require it for legitimate business purposes.16. Cookies and our websiteOur website may use technologies that are necessary for it to function properly.We do not currently use the website for behavioural advertising or to track visitors across other websites.If we introduce analytics, advertising or other technologies that require consent or additional information under applicable law, we will update our practices and this Privacy Policy as necessary.Our website may contain links to third-party websites, such as LinkedIn. Those organisations are responsible for their own privacy practices.17. Changes to this policyWe may update this Privacy Policy from time to time to reflect changes to our business, technology, services or legal obligations.The latest version will be published on our website with the date it was last updated.18. Contact usIf you have questions about this Privacy Policy, how we use your information or wish to exercise a data protection right, contact:Harvey Clear trading as Defining Impact[email protected]