Passive Acquisition is committed to protecting your personal information and handling it responsibly, transparently and securely.
This Privacy Policy explains what information we collect, why we collect it, how we use it, who we may share it with, how long we retain it and the rights available to you under UK data protection law.
1. Who We Are
Passive Acquisition is a specialist engineering recruitment consultancy operated by Nicholas Fisher as a sole trader.
For the purposes of UK data protection law, Passive Acquisition is the data controller responsible for the personal information covered by this Privacy Policy.
Contact:
enquiries@passiveacquisition.co.uk
2. Information We May Collect
Candidates
We may collect:
- Your name
- Email address
- Telephone number
- Location
- Current or previous job titles
- Employment history
- Professional experience and skills
- Qualifications and professional memberships
- Salary expectations
- Notice period or availability
- Preferred locations and working arrangements
- LinkedIn or other professional profile information
- Your CV
- Cover letters
- Supporting documents you choose to provide
- Roles or types of opportunities you are interested in
- Correspondence and notes arising from discussions with you
- Information relating to applications you make through Passive Acquisition
Where appropriate later in a recruitment process, we may also request additional information required to support recruitment, compliance or eligibility checks.
We will not ask you to upload passports, right-to-work documents or similarly sensitive identification documents through the general website application form unless specifically required through an appropriate process.
Clients and Prospective Clients
We may collect:
- Your name
- Company
- Job title
- Business email address
- Telephone number
- Vacancy and recruitment requirements
- Job descriptions and specifications
- Correspondence and information provided during discussions with Passive Acquisition
Website Visitors and General Enquiries
We may collect:
- Your name
- Email address
- Telephone number where provided
- Company information where provided
- Information contained within an enquiry
- Basic technical information necessary for the operation and security of the website
3. How We Obtain Personal Information
We may receive personal information:
- Directly from you through our website, email, telephone or other communications
- Through a job application or candidate registration
- Through publicly available professional sources such as LinkedIn
- Through recruitment platforms or job boards
- Through referrals or professional introductions
- From clients where information is relevant to a recruitment process
Where we obtain candidate information from somewhere other than directly from the individual, we will provide appropriate privacy information when we first contact the individual or otherwise within the period required by applicable data protection law.
4. How We Use Candidate Information
We may use candidate information to:
- Assess your suitability for a vacancy
- Discuss employment opportunities with you
- Match your experience against client requirements
- Manage applications submitted through Passive Acquisition
- Communicate with you throughout a recruitment process
- Present your details to prospective employers where you have agreed to be represented
- Arrange interviews and support the recruitment process
- Maintain appropriate records relating to applications and recruitment activity
- Respond to candidate enquiries
- Consider you for future opportunities where you have chosen to opt in
Passive Acquisition will not submit your CV or candidate profile to a prospective employer without your knowledge and agreement.
5. Future Opportunities
When applying for a specific vacancy, you will have the option to consent to Passive Acquisition retaining your candidate information for future relevant opportunities.
This consent is optional and will not affect your application for the vacancy you are applying for.
Where you opt in, Passive Acquisition may retain your CV and relevant candidate information for up to 24 months for the purpose of identifying and discussing suitable future opportunities with you.
You may withdraw this consent at any time by contacting candidates@passiveacquisition.co.uk.
Withdrawing consent will not affect the lawfulness of any processing that took place before your consent was withdrawn.
General Candidate Registration
Where you use the Register Your Interest service, the purpose of the registration is to allow Passive Acquisition to retain your information and contact you regarding relevant opportunities.
Candidate information submitted through general registration will be retained for up to 24 months, unless you withdraw your registration earlier.
6. Applications Where Future Retention Is Not Selected
If you apply for a specific vacancy but do not opt in to consideration for future opportunities, your information will only be retained for as long as reasonably necessary to manage that recruitment process and associated administration.
As a general rule, this information may be retained for up to six months following the conclusion of the relevant recruitment process, unless there is a legal, regulatory or legitimate reason requiring it to be retained for longer.
It will not subsequently be used to approach you about unrelated future vacancies unless you have separately agreed to this.
7. Client Information
We use client and prospective client information to:
- Respond to recruitment enquiries
- Discuss current or anticipated vacancies
- Understand recruitment requirements
- Prepare vacancy advertisements and candidate searches
- Provide recruitment services
- Communicate regarding candidates and recruitment processes
- Maintain appropriate commercial and administrative records
- Manage contractual relationships and Terms of Business
Submitting a client enquiry does not automatically subscribe you to unrelated marketing communications.
8. Our Lawful Bases for Processing
Under UK data protection law, we must have a lawful basis for processing personal information.
Legitimate Interests
We may process information where reasonably necessary to operate a specialist recruitment consultancy, including assessing candidate suitability, managing recruitment processes, responding to enquiries, identifying potentially relevant professional candidates, maintaining appropriate business records, and protecting the security and integrity of our services.
Where we rely on legitimate interests, we consider the impact on the individual's privacy and data protection rights.
Consent
We rely on consent where you specifically choose to allow us to retain your candidate details for future opportunities. You can withdraw that consent at any time.
Contractual Purposes
We may process information where necessary to take steps towards entering into a business relationship or to provide recruitment services under an agreed contract.
Legal Obligations
We may process or retain information where necessary to comply with legal, regulatory, accounting or other statutory requirements.
9. Special Category Information
Some personal information is considered particularly sensitive under data protection law, including information concerning health, ethnicity, religion, political opinions, trade union membership, sexual orientation and certain biometric or genetic information.
Passive Acquisition does not generally require this information at the initial application or registration stage.
If special category information is provided or becomes necessary during a recruitment process, it will only be processed where there is an appropriate lawful basis and additional legal condition permitting its use.
Candidates should avoid including unnecessary sensitive personal information in CVs or supporting documents.
10. Sharing Candidate Information
Candidate information may be shared with:
- Prospective employers where you have agreed to be represented for an opportunity
- Service providers used to operate our website, application forms, email, document storage or other business systems
- Professional advisers where reasonably necessary
- Regulators, courts, law enforcement agencies or other authorities where disclosure is legally required
Service providers acting on our behalf will only be permitted to process information for appropriate business purposes and subject to applicable data protection requirements.
We do not sell candidate or client personal information.
11. Confidential Vacancies
Some clients choose to conduct recruitment confidentially.
Where this applies, Passive Acquisition may advertise or discuss an opportunity without initially identifying the organisation.
Candidate information will not be submitted to a confidential client without the candidate being informed and agreeing to be represented for the opportunity.
12. Data Retention
We only retain personal information for as long as it is reasonably required for the purpose for which it was collected.
- Specific vacancy applications without future-opportunity consent: Up to six months after the relevant recruitment process concludes.
- Candidates opting in to future opportunities: Up to 24 months.
- General candidate registrations: Up to 24 months.
- Client and commercial records: For as long as reasonably required to manage the business relationship and satisfy applicable legal, contractual, accounting or regulatory obligations.
- General enquiries: For only as long as reasonably necessary to respond to and administer the enquiry.
At the end of the relevant retention period, information will be securely deleted or anonymised unless there is a lawful reason to retain it for longer.
13. Data Security
Passive Acquisition takes reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration, disclosure and accidental destruction.
Access to candidate and client information will be limited to those who reasonably require it for the operation of Passive Acquisition and the recruitment services being provided.
14. International Data Transfers
Some technology or service providers used by Passive Acquisition may store or process information outside the United Kingdom.
Where this occurs, Passive Acquisition will take appropriate steps to ensure that personal information receives an appropriate level of protection in accordance with UK data protection requirements.
15. Your Data Protection Rights
Depending on the circumstances, you may have the right to:
- Request access to personal information held about you
- Request correction of inaccurate or incomplete information
- Request deletion of your information
- Request restriction of processing
- Object to certain processing
- Request transfer of information where applicable
- Withdraw consent where processing is based on consent
Not every right applies in every circumstance.
To exercise a data protection right or ask a question about your information, contact enquiries@passiveacquisition.co.uk.
We may need to verify your identity before responding to a request.
16. Complaints
If you have concerns about how Passive Acquisition has handled your personal information, please contact us first so that we can investigate the matter.
You also have the right to raise a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator.
Further information is available at ico.org.uk.
17. Cookies and Website Technology
Passive Acquisition may use cookies or similar technology that are strictly necessary for the website to operate securely and correctly.
If non-essential cookies, analytics or similar technologies are introduced, visitors will be provided with appropriate information and, where required, the ability to give or refuse consent before those technologies are used.
Further information may be provided in a separate Cookie Policy where appropriate.
18. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes to our services, technology, business processes or legal requirements.
The latest version will always be made available on the Passive Acquisition website, together with the date it was last updated.