Privacy Policy

Privacy Notice
Last updated: 28 July 2026

Recognition One respects your privacy and is committed to protecting your personal data.
This Privacy Notice explains how we collect, use, store and share personal data when providing recruitment, executive search, work-finding and related services, and when you use our website. It also explains how we use artificial intelligence and recruitment technology.
We process personal data in accordance with applicable data protection and privacy law, including the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 as amended, and applicable electronic communications legislation.

1. Who we are
Recognition One Limited is the controller responsible for the personal data covered by this notice unless we tell you otherwise.

Recognition One Limited
Company number: 08410264
The White Chapel Building
London
E1 8QS
United Kingdom

Email: info@recognitionone.com
Telephone: +44 (0)203 308 9140

References to “Recognition One”, “we”, “us” and “our” mean Recognition One Limited.

Where another Recognition One entity is responsible for a particular service or processing activity, we will identify that entity where required.

2. Who this notice applies to
This notice applies to:

• Candidates, prospective candidates and other adult work-seekers.
• Professionals we identify through executive search, candidate sourcing or talent research.
• Employees, representatives and contacts of clients and prospective clients.
• Referees and other people whose details are provided to us.
• Suppliers, consultants and business partners.
• Visitors to our website.
• People who receive job opportunities, market information or other business communications from us.

Recognition One’s recruitment and executive search services are not provided to people under the age of 18.

Our own employees and applicants for employment with Recognition One may receive separate privacy information where appropriate.

3. The personal data we collect

The information we collect depends on our relationship with you and the services involved.

Identity and contact information
This may include:

• Name.
• Job title.
• Email address.
• Telephone number.
• Postal address where relevant.
• Professional social media and networking profiles.
• Other professional contact information.

Career and professional information
This may include:

• CV or résumé.
• Employment history.
• Current and previous employers.
• Job titles and responsibilities.
• Professional achievements.
• Education.
• Qualifications and certifications.
• Professional memberships.
• Skills and expertise.
• Technical knowledge.
• Languages.
• Seniority and level of responsibility.
• Management and leadership experience.
• Industry and sector experience.
• Geographic location.
• Career interests and objectives.
• Preferred roles and locations.
• Willingness to travel or relocate.
• Availability and notice period.
• Remuneration expectations and, where lawful, other remuneration information relevant to a recruitment process.
• Right-to-work information where relevant.
• Information contained in publicly available professional profiles.

Recruitment information
This may include:

• Roles for which you are being considered.
• Applications and expressions of interest.
• Information you provide during calls, meetings or interviews
• Interview and meeting notes.
• Assessments made by our consultants.
• Client feedback.
• References.
• Results of lawful assessments, screening or verification checks where relevant.
• Records of candidate introductions.
• CV submissions.
• Interviews.
• Offers.
• Placements.
• Correspondence relating to recruitment processes.

Sourcing and search information
When carrying out recruitment research or executive search, we may process professional characteristics relevant to a particular search, such as:

• Skills.
• Technologies used.
• Sector or industry experience.
• Seniority.
• Job function.
• Current or previous employer.
• Type or size of company worked for.
• Length of professional experience.
• Tenure.
• Geographic location.
• Leadership or management experience.
• Qualifications.
• Other professional criteria relevant to a role or assignment.

Recruitment sourcing technology may generate or display information indicating how closely a professional profile appears to correspond with search criteria specified by one of our consultants.

This assists our sourcing activity. It does not determine whether a person is suitable for employment or whether they progress through a recruitment process.

Communications information
This may include:

• Emails.
• Telephone calls.
• Messages.
• Correspondence.
• Meeting and call notes.
• Call or meeting recordings where used.
• Transcripts.
• Summaries.
• Actions arising from calls or meetings.
• Communication preferences.
• Records of permissions or consent where applicable.

Client, supplier and business information
This may include:

• Employer and job title.
• Business contact details.
• Recruitment requirements.
• Hiring plans.
• Contractual information.
• Invoices.
• Payment and transaction information.
• Business correspondence.
• Information concerning our professional relationship.

Website and technical information
This may include:

• IP address.
• Browser and device information.
• Website usage information.
• Security and access logs.
• Cookie and similar identifiers.
• Information submitted using our website.

4. Special category and criminal offence information
Special category personal data includes information concerning:

• Race or ethnicity.
• Political opinions.
• Religious or philosophical beliefs.
• Trade union membership.
• Genetic information.
• Biometric information used for identification.
• Health.
• Sex life.
• Sexual orientation.

Recognition One does not routinely request or intentionally collect special category personal data as part of our recruitment services.

We ask individuals not to provide sensitive information that is unnecessary for a recruitment process.

There may be limited circumstances in which we need to process special category information, for example:

• Where you tell us about a disability or health condition so that reasonable adjustments can be made.
• To meet accessibility requirements.
• Where processing is necessary in connection with employment or social protection law.
• Where necessary to establish, exercise or defend legal claims.
• Where another condition permitted by data protection law applies.

Where we process special category personal data, we will ensure that we have both an appropriate lawful basis and an applicable legal condition permitting the processing.

We do not routinely carry out criminal record checks. Criminal offence information will only be processed where it is relevant, necessary and lawful, with appropriate safeguards in place.

5. How we obtain personal data
We may obtain information:

• Directly from you.
• From a CV, résumé, application or enquiry.
• Through our website.
• During telephone calls, video calls, meetings or interviews.
• Through correspondence with you.
• From professional networking platforms.
• From job boards and candidate databases.
• From recruitment and sourcing platforms.
• From publicly available professional profiles.
• From company websites.
• From conference or event materials.
• From professional publications.
• From public registers.
• From clients.
• From colleagues, referrals and professional contacts.
• From referees.
• From verification or screening providers where appropriate.
• From our CRM, applicant tracking system and other recruitment systems.
• From previous communications or dealings with you.

Candidate sourcing
Executive search involves identifying professionals who may be relevant to an opportunity even where they have not applied for a vacancy or previously contacted Recognition One.

We may use recruitment sourcing technology, including SourceWhale and SourceWhale Search where enabled, to assist with this process.

Depending on the functionality being used, this may involve searching:

• Candidate profiles.
• CVs and résumés.
• Employment information.
• Professional networking profiles.
• Publicly available professional information.
• Information in our CRM or ATS.
• Relevant recruitment notes.
• Previous communications.
• Call notes, transcripts or summaries stored within an integrated recruitment system.

If we obtain your personal data from somewhere other than directly from you, we will provide or make you aware of the relevant privacy information within the period required by law unless an exemption applies.

Where we contact you using information obtained through candidate sourcing, we will normally make you aware of this Privacy Notice at or before our first communication with you.

6. How we use personal data and our lawful bases
We only process personal data where we have an appropriate lawful basis.

Depending on the circumstances, we may rely on:

• Our legitimate interests.
• The legitimate interests of our clients or another organisation.
• Performance of a contract.
• Taking steps at your request before entering into a contract.
• Compliance with a legal obligation.
• Consent where appropriate.

Another lawful basis permitted by applicable law.

Recruitment and work-finding services
We use personal data to:

• Understand your experience, skills and career objectives.
• Identify opportunities that may be relevant to you.
• Discuss opportunities with you.
• Assess professional information.
• Introduce you to clients.
• Submit your CV or profile to clients with your knowledge or agreement.
• Arrange interviews.
• Manage recruitment processes.
• Obtain and communicate feedback.
• Support negotiations and offers.
• Assist with onboarding and placements.
• Maintain records of our relationship with you.

Our lawful basis will normally be our legitimate interests in providing recruitment services, steps taken at your request before entering into a contract, contractual necessity, or a combination of these depending on the circumstances.

Executive search and candidate sourcing

We research and identify professionals who may be relevant to opportunities for our clients.

This can include people who:

• Have never contacted Recognition One.
• Have not applied for a particular role.
• Are not actively looking for a new job.
• Have previously interacted with us.
• Are already contained in our recruitment systems.

Our lawful basis for this activity is normally our legitimate interests and, where relevant, our clients’ legitimate interests in identifying and engaging appropriately qualified professionals.

When relying on legitimate interests, we consider matters including:

• The professional nature of the information.
• How and where the information was made available.
• Your reasonable expectations.
• Its relevance to the recruitment activity.
• The potential impact on you.
• The safeguards and rights available to you.

You have the right to object to this processing. See section 15.

Client and business activities

We may process information about clients, prospective clients, suppliers and professional contacts to:

• Discuss recruitment requirements.
• Manage recruitment assignments.
• Provide executive search and recruitment services.
• Manage client relationships.
• Identify appropriate business opportunities.
• Negotiate and perform contracts.
• Manage suppliers.
• Issue invoices and process payments.
• Maintain financial and business records.
• Respond to enquiries.
• Manage complaints and disputes.
• Develop and protect our business.

Our lawful basis will normally be contractual necessity, steps taken before entering into a contract, legitimate interests or compliance with legal obligations.

Verification and legal purposes
Where appropriate and lawful, we may process personal data to:

• Verify identity.
• Verify employment history or qualifications.
• Obtain references.
• Verify right to work.
• Protect candidates, clients and Recognition One.
• Comply with legal and regulatory requirements.
• Manage complaints or disputes.
• Establish, exercise or defend legal claims.
• Obtain professional or legal advice where necessary.

7. Artificial intelligence and recruitment technology

Recognition One may use AI-enabled technology to support parts of our recruitment and business workflow.

AI-assisted sourcing and research

We may use technology such as SourceWhale Search to help our consultants identify potentially relevant professionals.

Depending on the functionality being used, the technology may:

• Interpret a description entered by a consultant.
• Convert that description into search criteria or an ideal profile.
• Search our recruitment database, CRM or ATS.
• Search CVs and other professional records.
• Search publicly available professional information.
• Identify potentially relevant professionals.
• Compare profiles with criteria specified by our consultant.
• Rank or order search results according to apparent relevance.
• Allow consultants to refine searches using professional characteristics such as skills, seniority, experience, location, employer or tenure.
• Take account of previous sourcing preferences where that functionality is enabled.

For example, a consultant may search for professionals with particular technical experience, seniority and geographic location. The technology may return profiles in an order reflecting how closely the available professional information appears to correspond with those criteria.

An AI-generated ranking, search result or relevance indicator is a sourcing aid. It is not a recruitment decision.

Our consultants review sourcing results and use their own professional judgement.

We do not automatically reject or exclude someone because they:

• Do not appear in an AI-generated search.
• Appear lower in search results.
• Receive a lower relevance indication.
• Appear to be a less close match than another profile.

AI-assisted sourcing may involve automated processing of professional information and, depending on the circumstances, may constitute profiling for data protection purposes.

Any such profiling is used to support candidate research and sourcing, not to make recruitment decisions.

AI-assisted administration

We may also use AI tools to assist with administrative activities such as:

• Call and meeting transcription.
• Note-taking.
• Summarising conversations.
• Creating draft action points.
• Organising information.
• Drafting routine communications.
• Assisting with job descriptions.
• Assisting with Boolean or other search strings.
• Researching companies.
• Summarising non-personal market information.

AI does not make our recruitment decisions
Recognition One does not use AI to make recruitment decisions about candidates.

People remain responsible for decisions concerning whether someone:

• Should be approached about an opportunity.
• Is considered suitable for a role.
• Should progress through a recruitment process.
• Should be interviewed.
• Should be introduced or recommended to a client.
• Should be shortlisted.
• Should receive an offer.
• Should be rejected from a recruitment process.

We do not use fully automated decision-making to determine recruitment outcomes.

Call recording, transcription and note-taking

We may use approved technology, including SourceWhale functionality, to record or transcribe calls or meetings and produce notes or summaries.

Where an AI-generated note, transcript or summary is relevant to a recruitment process, it should be reviewed by a member of our team before being materially relied upon.

AI-generated call notes are not used to make automated assessments of candidate suitability.

Where we propose to record or transcribe a conversation, we will tell participants and seek permission before using that functionality.

If a participant does not want an AI-enabled recording or transcription tool to be used:

• The recording or transcription function will not be used.
• Our consultant may take manual notes.
• A candidate will not be disadvantaged for declining AI-assisted recording or transcription.

AI safeguards

We require appropriate human oversight of AI-assisted systems.

Our staff are expected to:

• Use approved systems.
• Understand the purpose and limitations of the technology they use.
• Review material outputs where appropriate.
• Check relevant information for accuracy.
• Exercise independent professional judgement.
• Avoid treating AI rankings or outputs as recruitment decisions.
• Minimise unnecessary processing of personal information.
• Protect confidential candidate and client information.
• Follow our data protection, security and AI governance requirements.

We do not use AI for:

• Fully automated candidate rejection.
• Fully automated shortlisting.
• Fully automated hiring decisions.
• Fully automated offer decisions.
• Emotion recognition in recruitment or workplace interactions.
• Assessing suitability from facial expressions, voice characteristics or purported emotional state.
• Making recruitment decisions on the basis of sensitive or protected characteristics.

We provide proportionate guidance and training to staff who use AI systems.

Where the EU Artificial Intelligence Act applies to our activities, we will comply with the requirements applicable to the AI systems we use and our role in using them.

If our use of AI changes materially, particularly if we consider using AI for candidate assessment, evaluation or selection rather than sourcing or administration, we will assess the legal and data protection implications before introducing that use and update this notice where required.

8. Marketing and recruitment communications

We may use professional contact information to communicate about:

• Relevant employment opportunities.
• Recruitment services.
• Recruitment market information.
• Salary and hiring information.
• Professional events.
• Recognition One’s services.
• Other professional information that we reasonably believe may be relevant.

We send electronic communications only where permitted by applicable data protection and electronic marketing law.

Where consent is required, we will obtain it. Where the law allows us to rely on legitimate interests, we may do so where our interests are not overridden by your rights.

You can ask us to stop marketing communications at any time.

Electronic marketing communications will include an appropriate way to opt out where required.

Opting out of marketing will not prevent us from contacting you about an active recruitment process, placement, contract, enquiry or other service-related matter.

We may retain limited information necessary to ensure that an opt-out preference continues to be respected.

9. Who we share personal data with

We only share personal data where there is an appropriate and lawful reason to do so.

Clients and prospective employers

We may share candidate information with a client considering candidates for an opportunity.

We will normally discuss the opportunity with you and obtain your agreement before sending an identifiable CV or candidate profile to a client.

In executive search, we may initially discuss an anonymised or non-identifying candidate profile with a client.

Service providers

We use technology and service providers to support our recruitment and business operations.

These may include providers of:

• Recruitment CRM and applicant tracking systems.
• Candidate sourcing tools.
• AI-assisted talent search and relevance-ranking technology.
• SourceWhale services.
• Professional contact information and data enrichment.
• Email and business communications.
• Telephone and video conferencing.
• Call recording and transcription.
• AI-assisted meeting note-taking and summarisation.
• Cloud hosting and storage.
• IT and cybersecurity.
• Website hosting and analytics.
• Electronic document signing.

Where a supplier processes personal data on our behalf, we require appropriate contractual, confidentiality and security safeguards.

Depending on the service involved, a supplier may have its own responsibilities under data protection law. Where applicable, its own privacy information will explain its processing.

SourceWhale

We may use SourceWhale for functions including recruitment sourcing, candidate search, outreach, communications, call or meeting transcription, note-taking and recruitment workflow management.

Where SourceWhale Search is enabled, it may assist us in searching information within our recruitment systems and professional information available from publicly accessible sources.

It may compare professional information with criteria specified by our consultants and rank search results according to apparent relevance.

Recognition One remains responsible for how those results are used and for recruitment decisions made by our consultants.

Professional advisers and legal disclosures

We may share personal data with our professional advisers where this is reasonably necessary for them to provide services to Recognition One, for example in relation to accounting or legal advice.

We may also disclose personal data where we are required to do so by law, regulation, court order or a lawful request from a competent public authority.

We only disclose information that is reasonably necessary for the relevant purpose.

We do not sell personal data.

10. International transfers

Recruitment is an international activity. Candidates, clients and suppliers may be located outside the United Kingdom, and some technology providers may process information in other countries.

Where personal data is transferred internationally, we use an appropriate legal transfer mechanism where required.

This may include:

• UK adequacy regulations.
• EU adequacy decisions where EU GDPR applies.
• The UK International Data Transfer Agreement.
• The UK Addendum to the European Commission Standard Contractual Clauses.
• European Commission Standard Contractual Clauses where applicable.
• Other legally recognised safeguards or transfer mechanisms.
• A permitted legal exception in appropriate circumstances.

Where required, we consider the risks associated with the destination country and implement appropriate contractual, organisational or technical safeguards.

You may contact us if you would like further information about the safeguards applicable to a particular transfer.

11. Do you have to provide personal data?

In most circumstances, you are not legally required to provide personal data to Recognition One.

However, certain information may be necessary for us to:

• Provide recruitment services.
• Progress you in relation to an opportunity.
• Introduce you to a client.
• Verify information relevant to a role.
• Verify your right to work where necessary.
• Enter into or perform a contract.
• Meet legal or regulatory obligations.

If you choose not to provide information that is necessary for a particular purpose, we may be unable to provide the relevant service or progress the relevant recruitment process.

12. How long we keep personal data

We keep personal data only for as long as reasonably necessary for the purposes for which we use it and to meet legal, regulatory, accounting, contractual and dispute-resolution requirements.

Different types of information may therefore be retained for different periods.

Candidate and prospective candidate records

As a general rule, candidate profiles, CVs, recruitment correspondence and related records are retained for up to two years following our last meaningful contact or recruitment activity with you.

We may retain information for longer where:

• We have an active professional relationship with you.
• You are involved in an ongoing recruitment process or placement.
• We reasonably expect further relevant engagement.
• A longer period is required by law.
• The information is needed for a complaint, dispute or legal claim.
• We have another appropriate and lawful reason to retain it.

When information is no longer required, we will delete or anonymise it where appropriate.

Candidate sourcing information

Information relating to professionals identified through candidate sourcing or executive search will normally be subject to the same retention approach.

If you ask us not to contact you, we may retain limited information necessary to ensure that your preference is respected.

Recruitment agency records

Where the Conduct of Employment Agencies and Employment Businesses Regulations 2003 apply, Recognition One retains the records required by those regulations for at least the applicable statutory period.

Relevant records must generally be retained for at least 12 months after their creation and for at least 12 months following the date on which we last provided relevant work-finding services to the work-seeker or hirer.

We are not required under those recruitment agency record-keeping rules to retain a speculative CV where we take no action to find work for that person.

Client, placement and financial information

Contracts, placement information, invoices and related financial records will normally be kept for the period necessary to meet contractual, tax, accounting and legal requirements, commonly six years where applicable.

Call recordings, transcripts and AI-generated notes

Raw recordings, transcripts and other AI-generated meeting material are retained only for as long as reasonably necessary for the purpose for which they were created.

Where information from a call or meeting forms part of an appropriate recruitment or business record, a reviewed note or summary may be retained for the retention period applicable to that record.

Recordings or transcripts may be kept for longer where necessary in connection with a complaint, investigation, dispute, legal claim or legal obligation.

Marketing preferences

We retain information relating to active marketing while we have an appropriate lawful basis to use it.

Where you opt out, we may retain a minimal suppression record for as long as necessary to ensure that we continue to respect that request.

Complaints and legal matters

Records relating to complaints, disputes, rights requests or legal claims may be retained for the period necessary to resolve the matter and take account of relevant limitation periods.

Anonymous information that can no longer identify an individual may be retained for longer.

13. Data security

We use appropriate technical and organisational measures designed to protect personal data against:

• Unauthorised access.
• Unlawful use.
• Accidental loss.
• Destruction.
• Damage.
• Unauthorised alteration.
• Unauthorised disclosure.

These measures may include:

• Access controls.
• Authentication.
• Encryption.
• Secure backups.
• Security monitoring.
• Supplier due diligence.
• Confidentiality requirements.
• Policies and procedures.
• Staff training.
• Appropriate technical security controls.

Access to personal data is restricted to people who have an appropriate business need to use it.

If a personal data breach occurs, we will investigate it and make any notifications required by law.

14. Your data protection rights

Depending on the circumstances and applicable law, you may have the right to:

• Ask whether we process your personal data.
• Obtain a copy of your personal data.
• Ask us to correct inaccurate information.
• Ask us to complete incomplete information.
• Ask us to erase personal data.
• Ask us to restrict processing.
• Object to processing based on legitimate interests.
• Object to direct marketing.
• Receive certain information in a portable format.
• Ask for certain information to be transferred to another organisation.
• Withdraw consent where processing is based on consent.
• Raise concerns about profiling or automated processing.
• Exercise protections relating to significant decisions made solely through automated processing where applicable.

Recognition One does not make recruitment decisions about individuals solely through automated processing.

Some rights are subject to legal conditions and exemptions.

For example, we may need to retain information where required by law or where it is necessary to establish, exercise or defend legal claims.

To exercise your rights, contact:
info@recognitionone.com

We may ask you for information necessary to verify your identity.

You will not normally have to pay a fee to exercise your rights. Where permitted by law, we may charge a reasonable fee or refuse to act on a request that is manifestly unfounded or excessive.

We will respond within the period required by applicable law.

15. Your right to object

Where we process your personal data on the basis of legitimate interests, you have the right to object to that processing.

This includes personal data used for:

• Candidate sourcing.
• Executive search.
• Talent research.
• Certain recruitment communications.
• Other activities where our lawful basis is legitimate interests.

If we have identified you through a professional network, public source or AI-assisted sourcing tool, you may ask us:

• Not to contact you about employment opportunities.
• Not to include you in active sourcing.
• To correct inaccurate professional information.
• To delete information where your right to erasure applies.
• To tell you where we obtained your information.

For further information about how AI-assisted sourcing has been used in relation to you.

You can object by emailing:

info@recognitionone.com

If you object to direct marketing, we will stop using your information for that purpose.

For other processing based on legitimate interests, we will consider your objection in accordance with applicable data protection law.

16. Data protection complaints

If you are concerned about how Recognition One has used your personal data, please contact us first at:

info@recognitionone.com

We have a process for receiving and handling data protection complaints.

We will:

• Provide an appropriate way for you to raise a complaint.
• Acknowledge a data protection complaint within 30 days.
• Investigate the complaint appropriately.
• Take appropriate steps in response to our findings.
• Keep you appropriately informed.
• Communicate the outcome without undue delay.

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

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom

Telephone: 0303 123 1113

Where EU data protection law applies, you may also have the right to complain to an appropriate supervisory authority in the European Economic Area.

17. Cookies and similar technologies

Our website may use cookies and similar storage or access technologies.

These may be used for:

• Essential website functionality.
• Security.
• Fraud prevention.
• Remembering preferences.
• Website statistics and analytics.
• Advertising or marketing.

Where consent is required by law, we will obtain consent before using non-essential technologies.

Certain technologies may be used without consent where an exemption under applicable law applies.

Where required, you can manage your choices through our cookie controls.

Our separate Cookie Notice provides or will provide further information about the technologies we use, their purposes and relevant providers.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

18. Accuracy of information

We take reasonable steps to ensure that personal data is accurate and, where relevant, up to date.

Professional information can change frequently, so we encourage you to tell us if information we hold becomes inaccurate or out of date.

Information obtained from public sources or third-party systems may occasionally be incomplete or outdated. Our consultants take this into account, particularly where AI-assisted sourcing technology is used.

19. Third-party websites

Our website and communications may contain links to websites or services operated by other organisations.

Those organisations are responsible for their own privacy practices.

We recommend reviewing their privacy information before providing personal data to them.

20. Information about other people

If you provide us with personal information about another person, such as a referee, you should ensure where appropriate that:

• You are entitled to provide the information.
• It is accurate.
• The person understands that their information may be provided to Recognition One.

You direct them to this Privacy Notice where appropriate.

21. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in:

• Our services.
• Our technology.
• Our use of AI
• Our suppliers.
• Applicable law.
• Regulatory guidance.
• Our business.

The current version will be published on our website and will state when it was last updated.

Where a change materially affects how we use existing personal data, we will take appropriate steps to bring the change to the attention of affected individuals where required.

22. Contact us
For questions about this Privacy Notice, our use of personal data, candidate sourcing, AI-assisted recruitment, your data protection rights or a complaint, contact:

Recognition One Limited
The White Chapel Building
London
E1 8QS
United Kingdom
Email: info@recognitionone.com
Telephone: +44 (0)203 308 9140