This policy uses layered, plain-language information. A specific service, platform or assessment may provide an additional notice where more detail is needed.
About this policy
This Privacy Policy explains how Impel Talent Ltd collects, uses, stores and shares personal information. It applies when you use this website, contact us, apply for or discuss an opportunity, attend an event, receive recruitment, coaching, assessment or leadership development services, work with us as a client or supplier, or otherwise interact with Impel Talent.
Some services, platforms or assessments may have an additional privacy notice where more specific information is needed. If there is a conflict, the more specific notice will apply to that activity.
Who we are and how to contact us
Impel Talent Ltd is the controller responsible for the personal information described in this policy unless another notice states otherwise.
Information we may collect
Candidates and potential candidates
Identity and contact details, CV and career history, education, skills, role preferences, remuneration expectations, work eligibility, availability, interview notes, references, assessment results and other information relevant to a role.
Clients and prospective clients
Business contact details, role and organisation information, enquiry and meeting records, service requirements, proposals, contracts, billing information and communications.
Delegates, coachees and assessment participants
Contact and professional details, programme enrolment, attendance, goals, feedback, assessment responses, coaching administration and information needed to deliver and evaluate the agreed service.
Website visitors and people who contact us
Form entries, prospectus or resource requests, booking details, correspondence, IP address, device and browser information, consent preferences and website usage data where permitted.
Suppliers, partners and professional contacts
Business contact details, contract and payment information, correspondence, professional information and records needed to manage the relationship.
Marketing and event contacts
Contact details, communication preferences, event attendance and interactions with newsletters, invitations, reports or other content.
Please do not provide personal information about another person unless you are authorised to do so and they have been given appropriate privacy information.
Where information comes from
We may collect personal information:
- directly from you through forms, email, telephone, meetings, applications, events or service delivery;
- from clients, referees, colleagues, suppliers or another person who introduces or refers you;
- from publicly available professional sources, including company websites, professional directories, LinkedIn and job platforms;
- from recruitment platforms, job boards, applicant systems, assessment providers or event platforms;
- through website technologies, subject to your cookie choices; and
- from records created during our relationship with you.
Where we obtain information from another source, we will provide privacy information within the period required by law, unless an exemption applies.
How and why we use personal information
| Purpose | Examples | Typical lawful basis |
|---|---|---|
| Responding to enquiries | Contact requests, consultations, programme prospectuses, bookings and service questions. | Legitimate interests and, where relevant, steps taken at your request before a contract. |
| Recruitment and talent services | Identifying, assessing and discussing opportunities, introducing candidates with appropriate authority, arranging interviews and managing placements. | Legitimate interests, contractual steps, performance of a contract and legal obligations. |
| Leadership, coaching and assessment services | Enrolment, administration, delivery, participant support, feedback, reporting and agreed programme evaluation. | Performance of a contract, legitimate interests and consent where it is specifically required. |
| Client and supplier relationships | Proposals, contracts, project delivery, invoicing, payment, supplier management and business communications. | Performance of a contract, legitimate interests and legal obligations. |
| Website operation and security | Form processing, spam and abuse prevention, troubleshooting, access logs and protection of systems and users. | Legitimate interests and legal obligations. Strictly necessary technologies may be used without optional cookie consent. |
| Analytics and service improvement | Understanding website use, content performance and user journeys, where optional analytics are enabled. | Consent for non-essential website technologies. |
| Marketing and professional updates | Newsletters, events, reports, relevant opportunities and service communications. | Consent or legitimate interests where electronic marketing law permits, with a clear right to opt out. |
| Legal, regulatory and business protection | Record keeping, tax and accounting, disputes, claims, due diligence, fraud prevention and responding to lawful requests. | Legal obligations and legitimate interests. |
Where we rely on legitimate interests, those interests include operating and improving our services, supporting candidates and clients, developing professional relationships, protecting our systems and establishing or defending legal rights. We consider the impact on individuals before relying on this basis.
Sensitive information
We do not ask for special category information or criminal-offence information unless it is relevant and lawful for a particular service, role, assessment, adjustment, safeguarding requirement or voluntary diversity initiative.
This may include information about health or disability where an adjustment is requested, or voluntary diversity information. We use additional safeguards and an appropriate condition under data protection law. Where explicit consent is the appropriate condition, it can be withdrawn, although this will not affect processing already carried out lawfully.
Who we may share information with
Depending on the service and only where appropriate, we may share information with:
- clients or prospective employers, normally after discussing the relevant opportunity or purpose with the candidate;
- coaches, facilitators, assessors, consultants and delivery partners involved in an agreed service;
- technology, hosting, email, recruitment, CRM, document storage, analytics, booking, video, podcast, form and security providers;
- professional advisers, insurers, auditors, accountants and legal advisers;
- regulators, public authorities, courts or law-enforcement bodies where required or permitted by law;
- companies involved in a genuine restructuring, investment, merger or sale, subject to appropriate confidentiality and data protection measures.
Service providers are permitted to use information only for the relevant service and subject to contractual or other appropriate protections. Some third-party platforms may also act as independent controllers under their own privacy terms.
International transfers
Impel Talent works internationally and some clients, candidates, service providers or technology systems may be located outside the United Kingdom. Where personal information is transferred internationally, we use an available lawful transfer mechanism and appropriate safeguards, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful exception.
You may contact us for more information about the safeguards relevant to your information.
How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including service delivery, professional relationship management, legal, accounting, tax, insurance, regulatory and dispute requirements.
When deciding the retention period, we consider:
- the nature, sensitivity and amount of the information;
- whether an active candidate, client, participant, supplier or professional relationship continues;
- the expectations communicated at the time of collection;
- contractual, statutory, limitation, tax, insurance and regulatory periods;
- whether the information remains accurate and relevant; and
- the risk of harm from unauthorised use or disclosure.
Information that is no longer required is deleted, anonymised or securely archived in accordance with our retention processes.
Security
We use proportionate technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, disclosure, access or misuse. Measures may include access controls, authentication, secure hosting, backups, staff procedures, supplier due diligence and contractual controls.
No internet or storage system is completely secure. If you believe information connected with Impel Talent has been misused, lost or accessed without authority, contact us promptly.
Your data protection rights
Depending on the circumstances and the lawful basis used, you may have the following rights:
- AccessReceive a copy of personal information we hold about you.
- CorrectionAsk us to correct incomplete or inaccurate information.
- ErasureAsk us to delete information where the legal conditions are met.
- RestrictionAsk us to limit how information is used in certain circumstances.
- ObjectionObject to processing based on legitimate interests or direct marketing.
- PortabilityReceive certain information in a structured, commonly used format.
- Withdraw consentWithdraw consent at any time where consent is the basis used.
- ComplainRaise a concern with us or the Information Commissioner's Office.
Your right to object
You have an absolute right to object to direct marketing. You may also object where we rely on legitimate interests, although we may continue processing if there are compelling legitimate grounds or the information is needed for legal claims.
To exercise a right, email info@impeltalent.com. We may need to verify your identity and clarify the request. We normally respond within one month, subject to extensions permitted by law for complex or multiple requests.
Marketing and communication preferences
We may send relevant professional updates, opportunities, invitations, reports or service information where you have consented or where another lawful route is available. Every electronic marketing message will provide a way to unsubscribe, and you can also contact us at any time.
Opting out of marketing does not prevent us from sending necessary service, contractual, recruitment-process, security or legal communications.
Automated tools, matching and assessments
We may use technology to support search, matching, administration, analytics or assessment activities. Unless we tell you otherwise in a specific process, Impel Talent does not make decisions through the public website based solely on automated processing that produce legal or similarly significant effects. Human judgement remains involved in recruitment and service decisions.
Questions and complaints
Please contact us first so that we can try to resolve a concern. You also have the right to complain to the UK Information Commissioner's Office.
Changes to this policy
We may update this policy when our services, technology, suppliers or legal obligations change. The latest version will be published on this page with an updated date. Where a change materially affects how existing information is used, we will take reasonable steps to bring it to the attention of affected individuals.