Privacy Notice

Winberg Associates Ltd. is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.


  1. Collection and use of personal data
  2. Purpose of processing and legal basis


The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.

In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

 The legal bases we rely upon to offer these services to you are:

  • Your consent

  • Where we have a legitimate interest

  • To comply with a legal obligation that we have

  • To fulfil a contractual obligation that we have with you 

  1. Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  • Managing our database and keeping your records up to date

  • Contacting you to seek your consent where needed

  • Providing work-finding services to you, including sending your information to clients where you have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on your CV

  • Contacting you with information about similar products or services that you have used from us recently

  • Passing your information to debt collection where requested.

  1. Recipient/s of data

The Company will process your personal data with the following recipients:


  • Property companies, consultancies, developers, banks, REITs, funds, institutions and private practices

  • Your former or prospective new employers that we obtain or provide references to

  • The Recruitment and Employment Confederation

  • Umbrella companies that we pass temporary candidate data to

  • Our legal advisers

  • Social networks

  • Our IT and CRM providers

  • Any other organisations that you ask us to share your data with

  1. Statutory/contractual requirement

Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are that we may not be able to introduce you to a client for work-seeking purposes.

  1. Overseas Transfers

The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

  1. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.

  1. Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;

  • The right of access to the personal data the Company processes on you;

  • The right to rectification of your personal data;

  • The right to erasure of your personal data in certain circumstances;

  • The right to restrict processing of your personal data;

  • The right to data portability in certain circumstances;

  • The right to object to the processing of your personal data that was based on a public or legitimate interest;

  • The right not to be subjected to automated decision making and profiling; and

  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting Lucy Winberg, Managing Director – tel: 0203 865 6207/email: lw@winbergassociates.com.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

  1. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it, in the first instance please contact: Lucy Winberg, Managing Director – tel: 0203 865 6207/email: lw@winbergassociates.com.

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

Annex A

  1. The lawfulness of processing conditions for personal data are:
  2. Consent
  3. Processing 
  4. Processing 
  5. Processing 
  6. Processing  data controller
  7. Processing  personal data
  • The lawfulness of processing conditions for sensitive personal data are:
    1. Explicit

       of the individual for one or more specified purposes, unless reliance on

      is prohibited by EU or Member State law.

    2. Processing 
    3. Processing  consent
    4. In the course of its legitimate activities

      is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the

      relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the

      of the individual.

    5. Processing personal data 
    6. Processing 
    7. Processing 
    8. Processing 
    9. Processing 
    10. Processing 


    Annex B

    Record Retention Policy

    Winberg Associates maintains records in line with our Data Protection Policy and those of the Information Commissioner’s Office (our registration number is ZA176406) to ensure that our business runs efficiently and in order to comply with statutory requirements.


    Winberg Associates ensures that all records are kept in accordance with the requirements of the Data Protection Act 1998. Extra care is taken with “sensitive personal data” (e.g. information captured in the Diversity Monitoring Form, CVs and our Customer Relationship Management system. We are not required to keep the original of all documents: copies can be stored in paper form or electronically (if stored electronically they are not alterable). All copies of original documents are verified to confirm that we have seen the original. Where the document contains a photograph of the individual we also confirm that the document provided is a true likeness to the individual.

    Any records that are no longer required are destroyed securely.