Privacy Policy & Recruitment Compliance Notice

Last updated: October 2025

1. Who we are

Init Source Ltd is a UK-based recruitment company acting primarily as an Employment Agency for permanent recruitment and, where applicable, an Employment Business.

Company name: Init Source Ltd
Company number: 16785993
Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: contact@initsource.co.uk

2. What personal data we collect

We may collect and process the following information:

We only collect information that is relevant to recruitment, candidate representation, client hiring, compliance, or related business purposes.

3. How we use your data

We use personal data to:

We do not sell personal data.

We will not submit your CV or identifiable candidate profile to an employer without your prior knowledge and permission for that specific opportunity.

4. Lawful basis for processing

We process personal data under the following lawful bases in accordance with UK GDPR:

You may withdraw consent at any time where we rely on consent.

Where we rely on legitimate interests, we do so only where we consider that our interests are not overridden by your rights, freedoms, or interests.

5. Special category and sensitive data

We do not intentionally collect special category data unless it is necessary for recruitment, right-to-work, reasonable adjustment, equality, legal, or compliance purposes.

Special category data may include information relating to health, disability, ethnicity, religious beliefs, or other protected characteristics where relevant and lawfully processed.

Where special category data is processed, we will only do so where a valid UK GDPR condition applies and appropriate safeguards are in place.

We do not request criminal record information unless it is relevant and lawful for the role or required by the Client or applicable law.

6. Who we share data with

Where relevant and appropriate, we may share personal data with:

Candidate data is shared only where relevant to genuine recruitment activity and, for CV submissions or identifiable candidate representation, with the candidate's prior knowledge and permission.

7. Data storage, security, and retention

We store personal data in secure systems with access restricted to authorised personnel.

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

Candidate records are normally retained for up to 12 months from our last meaningful contact with you, unless a longer period is required for legal, contractual, accounting, compliance, or dispute-resolution purposes.

Client and placement records may be retained for longer where necessary for contractual, legal, accounting, tax, compliance, or dispute-resolution purposes.

If you want us to delete your data sooner, you can contact us at contact@initsource.co.uk.

8. International data transfers

We do not routinely transfer personal data outside the UK.

Where international transfers are required, we will use appropriate safeguards such as the UK International Data Transfer Agreement, UK Addendum, Standard Contractual Clauses, or another lawful transfer mechanism.

9. Automated decision-making and AI tools

We do not use solely automated decision-making that produces legal or similarly significant effects.

Where technology or AI-assisted tools are used to support recruitment administration, screening, drafting, search, or communication, human review remains part of the recruitment process. Final recruitment decisions are not made solely by automated systems.

10. Your rights

Under UK data protection law, you may have the right to:

You can make a request by contacting: contact@initsource.co.uk

11. Complaints

If you have concerns about how your data is handled, please contact us first at contact@initsource.co.uk so we can try to resolve the issue.

You also have the right to lodge a complaint with the UK Information Commissioner's Office: ico.org.uk