Privacy Policy
Effective Date: August, 2025
1. Introduction
Johnson Elborne Ltd (“we”, “us”, “our”) is committed to protecting the privacy and confidentiality of personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. This Privacy Policy sets out the principles by which we process personal data collected through our website or in the course of our executive search and advisory services.
2. Data Controller
Johnson Elborne Ltd is the data controller of the personal data controller of the personal data described in this policy. We determine the purposes and manner which such data is processed.
3. Categories of Personal Data Collected
We may collect and process the following categories of personal data:
- Identity and contact details, including name, email address, telephone number, and company affiliation;
- Professional information, such as CVs, employment history, LinkedIn profiles, compensation expectations, and references;
- Technical data, such as IP address, browser type, device identifiers, and browsing patterns;
- Communications data, including correspondence, enquiry form submissions, meeting notes, and call records.
4. Method of Data Collection
We collect personal data:
- Directly from data subjects through forms, emails, and telephone interactions;
- Indirectly through public sources such as professional networking sites, company websites, and industry publications;
- Through referrals or professional introductions;
- Via third-party platforms and press reporting where appropriate and legally permissible.
5. Purpose and Legal Basis for Processing
Personal data is processed for the following purposes:
- The provision of executive search and advisory services;
- Assessment of suitability for client opportunities;
- Management of business relationships;
- Communication of relevant insights and opportunities, where permitted;
- Compliance with applicable legal or regulatory obligations.
Processing is carrier out on one or more of the following lawful bases:
- Legitimate interest;
- Consent (where voluntarily provided);
- Contractual necessity;
- Legal obligation.
6. Disclosure and Data Sharing
Personal data may be disclosed to the following categories of recipients:
- Internal employees and consultants, strictly for business purposes;
- Clients, only where express interest or consent has been given by the data subject;
- Approved third-party service providers operating under contractual agreements and confidentiality obligations;
- Legal or regulatory authorities where required by law.
International data transfers outside the UK or European Economics Area (EEA) are safeguarded by appropriate legal mechanisms such as Standard Contractual Clauses.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory requirements. Data subjects may request deletion of their personal data at any time.
8. Data Subject Rights
Pursuant to the UK GDPR, individuals have the right to:
- Access their personal data;
- Rectify inaccurate or incomplete data;
- Erase personal data (“right to be forgotten”)
- Restrict or object to the processing of their data;
- Withdraw consent at any time where processing is based on consent;
- Lodge a complaint with the UK Information Commissioner’s Office (www.ico.org.uk)
9. Security
We implement appropriate technical and organisational measures to ensure the security, integrity, and confidentiality of personal data under our control and to prevent unauthorised access, disclosure, or loss.
10. External Links
Our website may contain links to third-party websites. We are not responsible for the content, privacy policies, or data handling practices of such websites.
11. Updates to This Policy
This Privacy Policy may be amended periodically to reflect changes in legal requirements or business operations. The most current version will be published on our website.