Organisation Elva Talent Ltd
Effective date September 2026
Review At least annually and when material changes occur
1. Introduction
Elva Talent Ltd (Elva Talent) is a specialist permanent recruitment and executive search
business operating within the consumer goods sector across the UK, Europe and the USA.
We take the privacy and security of personal information seriously. This policy explains what information we collect, how and why we use it, where it comes from, who it may be shared with, how long it is retained and the rights available to individuals.
This policy applies to candidates and prospective candidates, individuals we identify or approach about career opportunities, clients and prospective clients, client contacts, suppliers, other business contacts and website users.
For UK data protection purposes, Elva Talent Ltd is the controller where we determine how and why personal information is processed.
2. Information we may collect
Name, telephone number, email address and general location.
CV, employment history, qualifications, skills, professional experience and publicly available professional
profile information.
Current and previous employers, job titles, responsibilities, remuneration, benefits, notice period, availability and career preferences.
Interview notes, assessment information, recruitment-process feedback and records of opportunities
discussed.
Right-to-work or eligibility information where appropriate.
Client and prospective-client contact information, recruitment requirements and business correspondence.
Telephone call recordings where calls are recorded through systems used by Elva Talent.
Technical information relating to website or electronic communications, where applicable.
Other information voluntarily provided in connection with our recruitment services.
3. How we obtain information
Information may be provided directly when you send a CV, contact us by email, telephone or LinkedIn, discuss an opportunity, apply for a role or engage with us as a client or business contact.
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As an executive search business, we also proactively identify and approach individuals. Professional information may therefore be obtained from LinkedIn, LinkedIn Recruiter, company websites and other legitimate public or professional sources. We may also receive information through referrals, clients, professional contacts and recruitment technology providers.
4. How we use personal information
Provide permanent recruitment and executive search services.
Identify, approach and assess people who may be suitable for current or future opportunities.
Understand candidates' experience, preferences and career objectives and match them with suitable
vacancies.
Represent candidates, arrange interviews, communicate feedback and support offer negotiations.
Maintain professional relationships with candidates and clients and discuss relevant future opportunities.
Understand client recruitment requirements, manage assignments and develop legitimate business
relationships.
Maintain appropriate recruitment and business records, improve services and protect our business and
systems.
Comply with legal, regulatory and contractual obligations and establish, exercise or defend legal claims.
5. Candidate representation and CV submission
Elva Talent will not ordinarily submit a candidate's CV or personally identifiable professional profile to a prospective employer in connection with a specific employment opportunity without first discussing the
opportunity with the candidate and obtaining their agreement to be represented.
This does not prevent confidential market mapping, executive-search research or discussion of talent in an
anonymised form where an individual cannot reasonably be identified.
6. Lawful bases for processing
Legitimate interests
We may process information where necessary for our legitimate interests or those of a third party, provided
those interests are not overridden by the individual's rights and interests. This can include operating a
recruitment business, sourcing suitable candidates, maintaining candidate and client relationships, matching people to opportunities and developing our services.
Contract
We may process information where necessary to enter into or perform a contract.
Legal obligation
We may process information where necessary to comply with legal or regulatory obligations.
Consent
Where consent is the appropriate basis for a specific activity, it may be withdrawn at any time without affecting processing already carried out lawfully.
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7. Special category information and equality
We do not routinely require special category information. Where such information is voluntarily provided or is necessary, for example to facilitate reasonable adjustments, it will be processed only where an appropriate lawful basis and additional legal condition applies.
Elva Talent is committed to fair recruitment and does not knowingly discriminate unlawfully on the basis of a protected characteristic.
8. Call recording
Telephone calls made or received through systems used by Elva Talent, including SourceWhale, may be
recorded. Recordings may be used for accurate record keeping, training and quality assurance, service
improvement, resolving queries or disputes, protecting legitimate interests and compliance or evidential
purposes where appropriate.
Individuals will be informed about recording where required. Call recordings will not be retained for longer than reasonably necessary for the purposes for which they were recorded.
9. Technology and service providers
Elva Talent currently uses Microsoft 365 / Office, LinkedIn, LinkedIn Recruiter and SourceWhale. These and
other appropriate providers may process personal information on our behalf or, in some cases, as independent controllers. We take reasonable steps to use reputable providers and appropriate data-protection safeguards.
10. Sharing personal information
Clients and prospective employers in connection with agreed recruitment processes.
CRM, communications, cloud-storage and other technology providers.
Professional advisers such as accountants, lawyers and insurers.
Authorities, regulators, courts or law-enforcement bodies where required.
Other service providers where reasonably necessary to operate the business.
We do not sell candidate personal information.
11. International recruitment and transfers
Elva Talent operates across the UK, Europe and the USA. Personal information may therefore be shared with
clients, candidates or service providers outside the UK. Where an international transfer is subject to UK data-protection rules, we will use an applicable lawful transfer mechanism or safeguard where required.
12. How long we keep information
Elva Talent retains personal information only for as long as is reasonably necessary for the purposes for which it was collected, including providing recruitment and executive search services, maintaining professional relationships and identifying and discussing relevant current or future opportunities.
Retention will vary according to the information, our relationship with the individual and the purpose of
processing. We periodically review information and securely delete or anonymise it when it is no longer
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required, subject to applicable legal, regulatory, contractual or legitimate business requirements. Certain
information may be retained for longer where necessary for legal claims. Call recordings may have shorter
retention periods than general candidate and client records.
13. Accuracy and security
We aim to keep information accurate and up to date and encourage individuals to tell us when relevant details change. Appropriate technical and organisational measures are used to protect information, including access controls, password protection, multi-factor authentication and secure cloud-based systems where available.
In the event of a personal data breach, we will investigate and take appropriate action, including notifications to regulators or affected individuals where legally required.
14. Direct marketing and professional communications
We may contact candidates about employment opportunities reasonably relevant to their professional
background and may contact existing or prospective clients about recruitment services where permitted by law.
Individuals may ask us to stop marketing communications at any time. This does not prevent necessary non- marketing contact relating to an active process, existing relationship or legal obligation.
15. Your data protection rights
Request access to personal information held about you.
Request correction of inaccurate or incomplete information.
Request deletion or restriction of processing in appropriate circumstances.
Object to certain processing, including direct marketing and, in some circumstances, processing based on
legitimate interests.
Request portability of certain information where the legal requirements apply.
Withdraw consent where processing relies on consent.
To exercise a right, contact privacy@elvatalent.com. We may need to verify identity and will respond within
applicable legal timeframes.
16. Automated decision-making
Elva Talent does not intend to make recruitment decisions about candidates solely through automated
processing where those decisions produce legal or similarly significant effects. Technology may assist sourcing, organisation, communication or matching, but our recruitment service involves human professional judgement.
17. Website, cookies and third-party links
Our website may use cookies and similar technologies for essential functionality, analytics or service
improvement. Where required, non-essential cookies will be used only after appropriate choices are provided. A separate Cookie Policy or cookie settings may provide further details.
We are not responsible for the privacy practices of third-party websites linked from our website or
communications.
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18. Complaints and contact
Questions or concerns should first be sent to privacy@elvatalent.com. You also have the right to complain to the UK Information Commissioner's Office where applicable, and individuals outside the UK may have rights to contact their local supervisory authority.
Elva Talent Ltd, 12 Stansfield Close, Bradford, BD10 0EN. Website: elvatalent.com. Privacy enquiries:
19. Changes to this policy
We may update this policy to reflect changes in our business, technology, services or legal requirements. The latest version will be published on our website with an updated date.