At Middleton White Limited we are committed to protecting your personal information. This privacy policy tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Our lawful bases for the collection and use of your data
• Where we get personal information from
• How long we keep information
• Who we share information with
• International transfer of personal information
• Cookies and analytics
• How to complain

Contact details

Email: contact@middletonwhite.co.uk

Post: Middleton White Limited, Coniston House, Boughton Hall Avenue, Woking, GU23 7DF

What information we collect, use, and why

We collect or use the following information for recruitment purposes:

• Contact details (e.g. name, address, telephone number or personal email address)
• Employment history (e.g. job application, employment references or secondary employment)
• Education history (e.g. qualifications)
• Right to work information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure - You have the right to ask us to delete your personal information.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing - You have the right to object to the processing of your personal data.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent - We have permission from you after we gave you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legal obligation - We have to collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests - We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability.

Our legitimate interests are the processing of personal data to match candidates with job opportunities and support hiring processes, and this is done in a fair, transparent, and proportionate way.

What this typically covers:

• Sourcing candidates - Collecting CVs, professional profiles, and contact details to identify suitable talent.
• Assessing suitability - Reviewing skills, experience, qualifications, and work history.
• Matching and presenting candidates to clients - Sharing relevant candidate details with potential employers.
• Managing recruitment processes - Arranging interviews, communicating updates, and maintaining records.
• Business development - Contacting potential candidates or clients where there is a reasonable expectation of interest in opportunities or services.

For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

Where we get personal information from:

• Directly from you
• Publicly available sources
• Previous employers

How long we keep information

Personal data is retained only for as long as necessary to fulfil recruitment purposes, comply with legal obligations, and protect business interests, after which it is securely deleted or anonymised.

We believe that it is reasonable and fair that we retain personal information in accordance with the following periods:

• Candidate data - We will retain your data for up to six years from last meaningful contact to support ongoing job matching, unless deletion is requested earlier.
• Contractor/temporary worker data - This will be held for the duration of the assignment and up to six years after, for legal, tax, and audit purposes.
• Placement and transaction records - Retained for six years to comply with UK tax, accounting, and legal requirements.
• Client data - This will be kept for as long as we provide recruitment services to you and for as long as it may be reasonable and commercially beneficial to us and to you.

Who we share information with

Others we share personal information with:

• Suppliers and service providers
• Other relevant third parties:
• Client organisations (employers) - Candidate details (e.g. CVs, skills, experience, contact information) are shared with hiring companies to assess suitability for roles.
• Business partners - In some cases, other recruitment agencies or partners where collaboration is needed to fill roles (with appropriate controls and transparency).

International transfer of personal information

Where we transfer personal information outside of the United Kingdom, we take steps to ensure that it is protected in line with UK data protection law.

This may include transferring data to countries that have been deemed to provide an adequate level of protection by the UK government, or using appropriate safeguards such as standard contractual clauses.

Where required, we ensure that additional measures are in place to protect your personal information.

You can contact us using the details at the top of this privacy notice for more information about how we safeguard international transfers.

Cookies and analytics

We use IONOS SiteAnalytics, a web analytics service provided by IONOS, to help us understand how visitors use our website and to improve its performance and user experience.

IONOS SiteAnalytics collects aggregated statistical information, such as the number of visitors, pages visited, and approximate location data. This information does not directly identify individuals.

IONOS SiteAnalytics does not use cookies to collect this information.

Analytics data is processed on servers located in Germany in accordance with applicable data protection laws.

If our use of cookies or similar tracking technologies changes in the future, we will update this privacy policy and, where required, request your consent.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us using the contact details at the top of this privacy notice, or to the Information Commissioner’s Office (ICO) who is the supervisory authority responsible for enforcing data protection laws in the UK. You can contact the ICO using live chat on their website, or call their helpline on 0303 123 1113.

We recommend that you read your right to make a complaint at: https://ico.org.uk/make-a-complaint/

Updated: 1 June 2026