Delve Recruitment Limited and Delve Search GmbH
Privacy Policy
Last updated: September 2026
1. Introduction
Delve Recruitment Limited and Delve Search GmbH (“Delve”, “we”, “us” or “our”) are committed to protecting your personal information and respecting your privacy.
This Privacy Policy explains how we collect, use, store, share and protect personal information in connection with our recruitment and search services, our business activities and our website.
This policy applies to:
• candidates and prospective candidates;
• clients and prospective clients;
• client employees and other business contacts;
• individuals applying to work for Delve;
• suppliers and service providers; and
• visitors to our website.
We process personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. Where Delve Search GmbH processes personal information subject to European Union data protection law, the EU General Data Protection Regulation (“EU GDPR”) will also apply.
2. Who is responsible for your personal information?
This Privacy Policy applies to Delve Recruitment Limited and its subsidiary, Delve Search GmbH, which together operate as part of Delve Search.
Delve Recruitment Limited and Delve Search GmbH share systems, policies and processes for the management of personal information. Depending on the particular processing activity, one or both entities may be responsible for determining how and why your personal information is processed.
Your primary contact for any questions about the use of your personal information or to exercise your data protection rights is:
Delve Recruitment Limited
18 Cheshire Business Park
Cheshire Avenue
Lostock Gralam
Northwich
Cheshire
CW9 7UA
United Kingdom
Email: info@delverec.com
Where your personal information is processed in connection with Delve Search GmbH, applicable EU and German data protection requirements will also be observed.
3. Personal information we collect
The information we collect depends on your relationship with Delve and the services we are providing.
Candidates and prospective candidates
We may collect and process information including:
• your name and contact details;
• CV and employment history;
• education, professional qualifications and skills;
• LinkedIn and other professional profile information;
• current and previous employers;
• current and expected salary, remuneration and benefits;
• notice period and availability;
• location, travel and relocation preferences;
• career interests and job preferences;
• information provided during telephone calls, emails, messages and meetings;
• call recordings and transcripts;
• recruiter notes and records of our interactions with you;
• information relating to roles we have discussed with you;
• applications, interview information and feedback;
• details of job offers and placements;
• references;
• right-to-work and immigration information where required;
• information necessary to establish your identity or suitability for a particular position; and
• any other information you choose to provide to us.
Clients, prospective clients and business contacts
We may collect and process information including:
• your name;
• job title;
• employer or company;
• business contact details;
• business address;
• information about recruitment requirements;
• records of telephone calls, meetings and correspondence;
• call recordings and transcripts;
• contractual and commercial information; and
• other information necessary to establish and manage our business relationship.
Job applicants
If you apply to work for Delve, we may collect information including your contact details, CV, employment history, qualifications, application information, interview notes, assessment information, references, right-to-work information and other information relevant to your application.
A separate employee privacy notice may apply where you become employed by Delve.
Website visitors
When you visit our website, we may collect certain technical information about your visit, including information about your device and browser and how you interact with our website.
We use Google Analytics and may use cookies and similar technologies to understand how our website is used.
Further information about the cookies and analytics technologies used on our website is provided in our Cookie Policy.
4. Special category and other sensitive personal information
In some circumstances, we may need to process information which is given additional protection under data protection law.
This may include information concerning health or disability where, for example, it is relevant to reasonable adjustments during a recruitment process.
We may also process information relating to criminal convictions or offences where this is necessary for a particular role and permitted by law.
We will only process this type of information where we have both a lawful basis for processing the personal information and, where required, an additional condition permitting us to process the relevant special category or criminal offence information.
We will only request and retain this information where it is necessary and proportionate.
5. How we obtain personal information
We may obtain personal information:
• directly from you;
• through telephone calls, emails, messages and meetings;
• from LinkedIn and other professional networking platforms;
• from publicly available professional and business sources;
• from job boards and recruitment platforms;
• through referrals and recommendations;
• from clients;
• from previous interactions with Delve;
• from referees or previous employers where appropriate; and
• from other third parties where permitted by law.
As a recruitment and search business, we may identify individuals who have not previously contacted Delve where we reasonably believe their professional experience may be relevant to a role or search we are undertaking.
Where we obtain personal information from another source, we will process it in accordance with applicable data protection requirements.
6. How we use personal information
Recruitment and search services
We may use personal information to:
• identify candidates and prospective candidates;
• search for individuals with relevant professional experience;
• assess experience and potential suitability for opportunities;
• contact individuals about career opportunities;
• understand career objectives and preferences;
• match candidates with client requirements;
• present or introduce candidates to clients;
• arrange interviews and meetings;
• obtain and communicate interview feedback;
• manage recruitment processes;
• manage offers and placements;
• maintain records of candidate and client interactions; and
• provide related recruitment and executive search services.
Client and business relationships
We may use personal information to:
• establish and manage client relationships;
• understand recruitment requirements;
• provide our services;
• enter into and administer contracts;
• communicate about recruitment assignments and placements;
• manage invoicing and payments;
• develop prospective business relationships;
• provide information about relevant Delve services; and
• maintain appropriate records of our business activities.
Administration, security and compliance
We may also process personal information to:
• administer our business;
• maintain accurate records;
• maintain and protect our systems;
• prevent or investigate fraud, misuse or inappropriate conduct;
• investigate complaints, incidents or disputes;
• protect Delve employees, candidates, clients and other individuals;
• establish, exercise or defend legal claims;
• respond to data protection requests;
• respond to law enforcement or regulatory requests where appropriate; and
• comply with legal, regulatory, tax and accounting obligations.
7. Our lawful bases for processing
Data protection law requires us to have a lawful basis for processing personal information.
Depending on the processing activity and our relationship with you, we may rely upon:
Legitimate interests
We may process personal information where this is necessary for our legitimate interests or those of a third party and those interests are not overridden by your rights and interests.
Our legitimate interests may include:
• providing recruitment and executive search services;
• identifying and contacting prospective candidates;
• matching candidates with appropriate opportunities;
• developing and maintaining client relationships;
• maintaining appropriate records of business communications;
• improving our services;
• protecting our employees and business;
• preventing and investigating disputes or misuse; and
• establishing, exercising or defending legal claims.
Where we rely on legitimate interests, we consider the necessity and proportionality of the processing and balance our interests against the potential impact on the individuals concerned.
Contract
We may process personal information where necessary to enter into or perform a contract with you.
Legal obligation
We may process personal information where necessary to comply with a legal or regulatory obligation.
Consent
In certain circumstances, we may ask for your consent.
Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent will not affect processing that took place before consent was withdrawn.
Not all processing carried out by Delve relies upon consent. Therefore, withdrawing consent will not necessarily require us to delete all information we hold about you.
8. Telephone calls, recordings and transcripts
We may record and transcribe telephone calls made to or from Delve.
Call recordings and transcripts constitute personal information where an individual can be identified from them.
We process recordings and transcripts where necessary for our legitimate business interests, including:
• maintaining accurate records of conversations;
• quality assurance and training;
• maintaining records relating to recruitment assignments, candidate discussions and client instructions;
• reviewing service standards;
• investigating complaints, disputes or incidents;
• protecting our employees, candidates, clients and business;
• establishing, exercising or defending legal claims; and
• meeting legal or regulatory requirements where applicable.
Where we rely on legitimate interests, we consider the necessity of the processing and balance our interests against the rights and interests of the individuals concerned.
Recordings and transcripts may be stored within our telephone and recruitment systems. Access is restricted to authorised personnel who require access for legitimate business purposes.
We do not retain call recordings or transcripts indefinitely solely because the technology used by Delve permits this.
Retention is determined according to the purposes for which the information is required and our applicable retention procedures.
Where a recording, transcript or associated record is relevant to a complaint, dispute, investigation, Subject Access Request, legal claim or regulatory matter, we may preserve it for longer where necessary.
9. Who we share personal information with
We do not sell personal information. Where necessary and appropriate, we may share personal information with:
• clients and prospective employers;
• candidates;
• companies within the Delve group;
• recruitment CRM and technology providers;
• telephone, communications and call-recording providers;
• email and collaboration providers;
• document management and electronic-signature providers;
• IT, cloud hosting and cybersecurity providers;
• website, analytics and marketing providers;
• HR, payroll and accounting providers;
• insurers;
• professional advisers, including accountants and lawyers;
• regulatory bodies;
• law enforcement agencies and other public authorities where required or appropriate; and
• other suppliers supporting the operation of our business.
Where an organisation processes personal information on our behalf, we take appropriate steps to ensure that suitable contractual, confidentiality and security arrangements are in place.
We will only share personal information where there is an appropriate reason and lawful basis for doing so.
10. Sharing candidate information with clients
As part of our recruitment services, it may be necessary to share candidate information with existing or prospective clients.
This may include information such as a candidate’s CV, professional experience, qualifications, skills, remuneration expectations, availability and other information relevant to assessing their suitability for a role.
We will only share identifiable candidate information with a client or prospective employer where there is an appropriate lawful basis for doing so and in connection with legitimate recruitment activities. Where appropriate, we will discuss the relevant opportunity with the candidate before submitting their information to a client.
Clients receiving candidate information are expected to handle it securely and in accordance with applicable data protection law.
11. International transfers
Delve operates internationally and uses technology and service providers that may store, access or process personal information in different countries.
Our principal recruitment CRM is hosted within the European Union. Our telephone and call-recording provider operates from France and within the European Union. We also use service providers, including document and electronic-signature platforms, which may store or process information in the European Union and the United States.
Personal information may therefore be transferred outside the United Kingdom and, where applicable, outside the European Economic Area.
Where personal information is transferred to a country that is not covered by an applicable adequacy decision or adequacy regulation, we take appropriate steps to ensure that an approved transfer mechanism and safeguards are in place.
Depending on the circumstances, these safeguards may include:
• UK adequacy regulations;
• European Commission adequacy decisions;
• the UK International Data Transfer Agreement;
• the UK Addendum to the EU Standard Contractual Clauses;
• EU Standard Contractual Clauses;
• an applicable recognised data-transfer framework; or
• another lawful transfer mechanism.
You may contact us at info@delverec.com for further information about safeguards relating to international transfers of your personal information.
12. How long we keep personal information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and while we continue to have an appropriate lawful basis for retaining it.
Retention periods may vary depending on:
• the type and sensitivity of the information;
• why the information was collected;
• our relationship with you;
• whether there is an active or reasonably anticipated recruitment or business relationship;
• whether the information remains relevant to our recruitment services;
• legal, tax, accounting and regulatory requirements;
• applicable limitation periods;
• contractual requirements; and
• whether the information is relevant to a complaint, dispute, investigation, data protection request or legal proceeding.
Candidate and business-contact records held within our recruitment systems are subject to periodic review. Where information is no longer reasonably required for recruitment, business, legal or compliance purposes, it will be deleted or anonymised in accordance with our retention procedures.
Call recordings and transcripts may be retained within our communications and recruitment systems. They will be retained only for as long as there remains an appropriate business, legal or compliance reason for doing so.
Where a particular record becomes relevant to a complaint, dispute, Subject Access Request, investigation, legal claim or regulatory matter, we may preserve it for longer than its usual retention period where necessary.
Certain records may be retained for longer periods where required by law or for accounting, contractual or legal purposes.
Where you ask us not to contact you or object to direct marketing, we may retain limited identifying information on a suppression list so that we can continue to respect your request.
13. Keeping personal information accurate
We take reasonable steps to ensure that the personal information we hold is accurate and, where necessary, kept up to date.
If you believe information we hold about you is incorrect or incomplete, please contact info@delverec.com.
14. Security
We take appropriate technical and organisational measures designed to protect personal information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
These measures may include:
• access controls and permissions;
• authentication and account-security measures;
• secure cloud-based systems;
• restrictions on access to personal information;
• appropriate contractual arrangements with suppliers;
• employee data protection and security requirements; and
• appropriate technical security measures.
Access to personal information is limited according to business requirements.
Although no electronic system or method of transmission can be guaranteed to be completely secure, we regularly consider the security measures appropriate to the information we process.
15. Your data protection rights
Depending on the circumstances and applicable law, you may have the right to:
Access – request a copy of personal information we hold about you.
Rectification – ask us to correct inaccurate or incomplete personal information.
Erasure – ask us to delete personal information in certain circumstances.
Restriction – ask us to restrict the way we process your personal information in certain circumstances.
Objection – object to processing based upon our legitimate interests in certain circumstances.
Direct marketing – object to the use of your personal information for direct marketing at any time.
Data portability – receive certain personal information in a structured, commonly used and machine-readable format and, where applicable, have it transferred to another organisation.
Withdraw consent – withdraw your consent where we rely upon consent as our lawful basis.
Automated decision-making – have certain rights where a significant decision about you is made solely through automated processing.
These rights are not absolute and exemptions or restrictions may apply depending on the circumstances.
You will not normally be charged for exercising your rights.
16. Subject Access Requests
You have the right to request access to personal information that we hold about you. This is commonly known as a Subject Access Request or SAR.
A request does not need to use the words “Subject Access Request” to be valid.
If you make a request, we may ask you to provide information reasonably necessary to confirm your identity or to help us identify the information you are requesting.
Where your request includes information relating to other individuals, we may need to redact or withhold some information in accordance with applicable data protection law.
We will respond to requests within the timescales required by applicable law.
To make a Subject Access Request or exercise another data protection right, please contact:
17. Marketing and your right to object
We may contact clients, prospective clients and other business contacts about Delve’s recruitment services where permitted by applicable data protection and electronic marketing laws.
You have the right to object to direct marketing at any time.
You can unsubscribe using the link included in our marketing communications or contact us at info@delverec.com.
If you opt out of marketing, this will not prevent us from contacting you where necessary to:
• provide recruitment services;
• manage an existing recruitment process;
• administer a contract or business relationship;
• respond to your enquiry; or
• comply with legal or regulatory obligations.
We may retain limited information about your preference so that we can continue to respect your decision not to receive marketing.
18. Automated processing and artificial intelligence
We may use technology, including systems incorporating artificial intelligence, to support our recruitment and business activities.
Such technology may assist our employees with activities such as searching, matching, organising, summarising or analysing information.
Technology may support our decision-making, but appropriate human involvement and oversight will be maintained where required.
We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect an individual unless we have a lawful basis for doing so and provide the safeguards required by applicable data protection law.
19. Website analytics and cookies
We use Google Analytics and cookies or similar technologies to understand how visitors use our website and to help us improve its performance and content.
Where consent is required for non-essential cookies or similar technologies, they will only be used after the appropriate consent has been obtained.
You can manage your cookie preferences using the controls provided on our website.
Further information about the cookies and technologies we use, their purposes and how long they remain on your device is provided in our separate Cookie Policy.
20. External websites
Our website may contain links to websites operated by other organisations.
We are not responsible for the privacy or security practices of external websites. We recommend reviewing the relevant organisation’s privacy information before providing personal information.
21. Complaints
If you have concerns about the way we handle your personal information, we encourage you to contact us first so that we can investigate and respond to your concerns.
Please contact: info@delverec.com
You also have the right to complain to the relevant data protection supervisory authority.
For matters relating to Delve Recruitment Limited in the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO).
For processing undertaken by Delve Search GmbH that is subject to the EU GDPR, you may also have the right to complain to the competent supervisory authority in Germany or another relevant EU supervisory authority.
22. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business, services, systems, suppliers or legal obligations.
The current version will be published on our website and the date at the beginning of this policy will show when it was last updated.
23. Contact us
For questions about this Privacy Policy, to exercise your data protection rights or to raise a concern about how your personal information is handled, please contact:
Delve Recruitment Limited
18 Cheshire Business Park
Cheshire Avenue
Lostock Gralam
Northwich
Cheshire
CW9 7UA
United Kingdom
Email: info@delverec.com