Privacy Policy
Last updated: 30 March 2026
1. Who We Are
Ncounter Limited (“Ncounter”, “we”, “us”, “our”) is a specialist technology recruitment agency based in London, UK. We provide permanent recruitment, contract recruitment, executive search, consultancy, and embedded talent solutions, with particular expertise in placing security-cleared professionals into roles within Defence, Critical National Infrastructure (CNI), and National Security programmes, as well as technology roles within fintech, Hedge Funds, and global Investment Banks.
We are a data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This means we are responsible for deciding how and why we hold and use your personal data.
This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what your rights are in relation to it.
2. Who This Policy Applies To
This policy applies to:
- Candidates – individuals who register with us, submit a CV, apply for a role, or are introduced to us for potential employment opportunities.
- Clients – businesses and organisations that engage us to source talent, manage hiring processes, or deliver consultancy services.
- Contacts – individuals whose details we hold for business development, referral, or networking purposes.
- Website visitors – individuals who visit ncounter.co.uk.
3. What Personal Data We Collect
3.1 Candidates
We may collect the following categories of personal data about candidates:
- Identity data: name, date of birth, photograph (where provided)
- Contact data: home address, email address, telephone number
- Professional data: CV, employment history, qualifications, skills, references
- Security clearance data: current clearance level, eligibility status, nationality, and right to work information
- Diversity data: where you choose to share it, data relating to equality and diversity monitoring – this is always voluntary
- Financial data: current and expected salary, day rate, payroll and IR35 status
- Communications data: records of correspondence, call logs, and notes from interviews or meetings
3.2 Clients
We may collect the following personal data about client contacts:
- Identity data: name and job title
- Contact data: business email address, telephone number, business address
- Business data: information about hiring needs, organisational structure, and programme requirements
- Communications data: records of correspondence and meeting notes
3.3 Website Visitors
When you visit our website, we may collect technical data such as IP address, browser type, and pages visited, as well as any information you submit via contact forms or job alert sign-ups.
4. How We Collect Your Data
We collect personal data through the following means:
- Directly from you: when you submit a CV, complete a form on our website, contact us by email or phone, or attend an event we organise
- Professional networks and job boards: publicly available profiles, job board applications, and referrals from existing candidates or clients
- Our recruitment systems: through your interactions with us recorded in our candidate and client management platforms
- Client organisations: where a client provides your details as part of a hiring brief or referral
5. Legal Basis for Processing
Under UK GDPR, we rely on the following legal bases to process your personal data:
| Legal Basis | When We Rely On It | Examples |
|---|---|---|
| Legitimate interests | Where processing is necessary for our legitimate business interests, provided these are not overridden by your rights | Sourcing and approaching passive candidates, maintaining candidate and client databases, business development |
| Performance of a contract | Where processing is necessary to fulfil a contract with you or take steps prior to entering one | Placing you into a role, managing a contractor engagement |
| Legal obligation | Where processing is required to comply with a legal or regulatory obligation | Right to work checks, tax and payroll compliance, security clearance verification |
| Consent | Where you have given us clear consent to process your data for a specific purpose | Sending marketing emails, using optional diversity data, sharing your CV with a named client |
Where we rely on legitimate interests, you have the right to object. See Section 10 for details of your rights.
6. How We Use Your Data
6.1 Candidates
- Assessing your suitability for current and future roles
- Introducing you to prospective employers or engaging organisations
- Managing your application through the recruitment process
- Conducting right to work, reference, and security clearance checks
- Keeping you informed of relevant job opportunities and market updates
- Administering contractor and payroll arrangements
- Complying with our legal and regulatory obligations
6.2 Clients
- Providing recruitment, search, and consultancy services
- Presenting suitable candidate profiles
- Managing ongoing business relationships and service delivery
- Sending relevant sector updates and event invitations
- Invoicing and financial administration
7. Who We Share Your Data With
We do not sell your personal data. We may share it with the following categories of recipients:
- Client organisations: with your knowledge, we share candidate profiles with relevant clients as part of the recruitment process
- Background check and verification providers: for reference, right to work, and security clearance checks
- Payroll and umbrella companies: where relevant for contractor engagements
- Technology service providers: third-party platforms we use to operate our business (see Section 7.1)
- Legal and regulatory authorities: where required by law, court order, or regulatory requirement
- Professional advisors: solicitors, accountants, and insurers under strict confidentiality obligations
7.1 Technology Service Providers
We use a number of third-party technology platforms to deliver our services, including tools for candidate and client management, communication, productivity, and website hosting. All providers are selected carefully and are required to handle personal data in accordance with applicable data protection law, under appropriate contractual safeguards.
Where any provider operates outside the UK, we ensure suitable transfer mechanisms are in place. You can request a current list of our key technology providers by contacting us at hello@ncounter.co.uk.
8. International Data Transfers
Some of our service providers operate outside the UK. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the ICO, adequacy decisions, or other legally recognised transfer mechanisms.
You may request further details of the safeguards in place for any specific transfer by contacting us at hello@ncounter.co.uk.
9. How Long We Keep Your Data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting obligations.
The appropriate retention period depends on the nature of the data, the purpose for which it is processed, and any applicable legal requirements. In determining how long to keep data, we consider the sensitivity of the information, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve the same purpose through less data.
When your data is no longer required, we will securely delete or anonymise it. If you would like further information about how long we retain specific categories of your data, please contact us at hello@ncounter.co.uk.
10. Your Data Protection Rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access: you can request a copy of the personal data we hold about you (a Subject Access Request).
- Right to rectification: you can ask us to correct inaccurate or incomplete data.
- Right to erasure: you can ask us to delete your data where there is no longer a lawful reason to hold it.
- Right to restrict processing: you can ask us to limit how we use your data in certain circumstances.
- Right to data portability: you can request your data in a structured, commonly used, machine-readable format.
- Right to object: you can object to processing based on legitimate interests or for direct marketing purposes.
- Rights related to automated decision-making: we do not use solely automated decision-making or profiling that produces legal or significant effects on individuals.
To exercise any of these rights, please contact us at hello@ncounter.co.uk. We will respond within one calendar month. We may need to verify your identity before processing your request.
You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
- Website: ico.org.uk
- Helpline: 0303 123 1113
11. Special Category Data and Security Clearances
Given the nature of our work in Defence, National Security, and CNI, we may handle data relating to security clearance eligibility, including nationality, right to work status, and clearance level. We treat this data with the highest level of care and process it only with your explicit consent or where necessary to carry out obligations under employment law.
We do not pass such data to third parties without your prior knowledge and consent, except where required by law or a client’s formal security protocols.
12. Cookies
Our website uses cookies to improve your browsing experience and to understand how visitors use our site. Cookies are small text files stored on your device. We use a combination of strictly necessary cookies (required for the site to function), analytics cookies (to understand usage patterns, set only with your consent), and functional cookies (to remember your preferences).
You can manage your cookie preferences through our cookie banner when you first visit the site, or through your browser settings at any time.
13. Direct Marketing
We may contact you with relevant job opportunities, sector news, and event invitations. Where we do so on the basis of legitimate interests, we will always ensure there is a genuine professional relevance to our communications.
You can opt out at any time by clicking the unsubscribe link in any email we send, or by contacting us at hello@ncounter.co.uk. Opting out of marketing will not affect any other communications necessary for our business relationship with you.
14. Third-Party Websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies before providing any personal data.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or operational requirements. When we make material changes, we will update the “Last updated” date at the top of this page. We encourage you to review this policy periodically.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Visit ico.org.uk or call 0303 123 1113.
