Privacy Policy

1. Introduction

Nardo Capital Consulting (“Nardo”, “we”, “us” or “our”) is an executive search and consulting organisation specialising in leadership appointments, talent intelligence and advisory services.

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We recognise that trust, discretion and confidentiality are fundamental to the relationships we develop with clients, candidates, business partners and professional contacts. Protecting personal information is an important part of that responsibility.

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This Privacy Policy explains how we collect, use, store, disclose and protect personal information in connection with our website, executive search activities, leadership advisory services, professional relationships and business operations.

 

We process personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, as amended, and the Privacy and Electronic Communications Regulations 2003 (PECR).

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2. Who We Are

Nardo Capital Consulting is a trading name of Nardo Capital Ltd, a company registered in England and Wales.

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For the purposes of applicable data protection legislation, Nardo Capital Ltd generally acts as the data controller of personal information collected and processed in connection with its business activities.

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Registered company name: Nardo Capital Ltd
Company registration number: 16445065
Registered office: Office 2 85 Priory Road, Kenilworth, Warwickshire, United Kingdom, CV8 1LQ
Data protection enquiries: info@nardocapital-consulting.com

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In certain client engagements, our role as a data controller, joint controller or data processor may differ according to the nature of the services and contractual arrangements.

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3. Information We Collect

The information we collect depends on the nature of our relationship with you.

Website visitors and general enquiries

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When you visit our website or contact us, we may collect:

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• Your name, email address, telephone number and organisation.

• Information provided through contact forms, emails, telephone conversations or other communications.

• Your IP address, browser type, device information and operating system.

• Website usage information, including pages visited, access times and technical performance data.

• Cookie preferences and information collected through permitted website technologies.

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Candidates and prospective executives

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In connection with executive search, leadership assessment, talent mapping and candidate representation, we may collect:

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• Name, professional contact details and location.

• Employment history, professional qualifications, skills and experience.

• Curriculum vitae, professional biographies and publicly available career information.

• Current and previous employers, areas of responsibility, seniority and relevant professional achievements.

• Career aspirations, mobility preferences, remuneration expectations and availability.

• Information obtained during professional discussions, interviews or assessments.

• Professional references, assessment results and other relevant information where appropriate and lawfully obtained.

• Records of our communications and interactions with you.

 

Clients, prospective clients and business contacts

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We may collect:

• Names, professional titles and business contact information.

• Company information and areas of professional responsibility.

• Information concerning organisational structure, leadership requirements and commercial priorities.

• Records of meetings, correspondence and business discussions.

• Information relevant to existing or prospective advisory and executive search engagements.

 

We seek to limit the information collected to what is relevant and reasonably necessary for the purposes described in this policy.

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4. How We Obtain Information

We may obtain personal information directly from you or from other legitimate sources, including:

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• Direct correspondence, enquiries, interviews and professional discussions.

• CVs, professional biographies and information you choose to provide.

• Professional networking platforms, including LinkedIn.

• Publicly available company websites, corporate announcements, professional directories and regulatory filings.

• Referrals and introductions from individuals within our professional network.

• Clients, employers and authorised representatives.

• Professional research, market intelligence and business information providers.

 

The fact that information is publicly accessible does not remove our responsibility to handle it lawfully, fairly and transparently.

 

Where we obtain personal information indirectly, we will provide appropriate privacy information within the timescales required by applicable law, subject to any lawful exceptions.

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5. How We Use Your Information

We process personal information for legitimate and specified business purposes.

 

Executive search and recruitment

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We may use professional information to identify, research, assess and engage individuals in connection with existing or potential leadership opportunities.

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This may include assessing professional experience, discussing relevant appointments, coordinating interviews and facilitating introductions between candidates and prospective employers.

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Candidate-to-Market and confidential representation

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Where an individual engages Nardo to explore professional opportunities, we may undertake targeted market research, identify relevant organisations and develop a considered approach to prospective employers.

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We recognise that confidentiality is particularly important where an individual is currently employed or wishes to explore the market discreetly.

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We will not disclose a candidate's identity, identifiable CV or confidential professional information to a prospective employer as part of a candidate introduction without the candidate's prior agreement to the intended disclosure.

Initial market engagement may be undertaken on an anonymised basis where appropriate. We will take reasonable steps to prevent anonymised profiles from inadvertently identifying the individual concerned.

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Leadership and organisational advisory

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We may process information to understand organisational requirements, provide leadership and talent advice, undertake market mapping, support succession planning and deliver agreed consulting services.

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Client relationships and business development

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We may use professional contact information to establish and maintain relationships, communicate about relevant services, respond to enquiries and identify potential opportunities for collaboration.

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Business administration and compliance

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We process information where necessary to administer commercial relationships, maintain appropriate records, manage contractual obligations, protect our legal interests and comply with applicable laws.

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Website operation

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We may process technical information to maintain website functionality, improve performance, understand permitted usage patterns, prevent misuse and protect our systems.

6. Our Lawful Bases for Processing

We only process personal information where there is an appropriate lawful basis under applicable data protection legislation.

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Depending on the circumstances, these may include:

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Legitimate interests

Where processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your rights and freedoms.

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These interests may include:

• Identifying and engaging suitably qualified executives for leadership opportunities.

• Conducting proportionate professional research and talent mapping.

• Maintaining relationships with candidates, clients and business contacts.

• Developing and delivering executive search and consulting services.

• Protecting our business, systems and commercial relationships.

 

Where we rely on legitimate interests, we consider the necessity and proportionality of the processing and its potential impact on the individuals concerned.

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Contractual necessity

 

Where processing is necessary to perform a contract with you or take steps at your request before entering into one.

 

Legal obligations

Where processing is necessary to comply with applicable legal, regulatory, accounting or reporting obligations.

 

Consent

Where consent is required or otherwise provides the appropriate lawful basis for a particular activity.

 

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing already undertaken lawfully.

 

We do not rely on consent as the universal lawful basis for our executive search and professional research activities.

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7. Sensitive Personal Information

Our services generally focus on professional experience, qualifications, leadership capabilities and other career-related information.

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We do not routinely seek sensitive personal information, including information concerning health, ethnicity, religious beliefs, political opinions or other special categories of personal data.

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Where such information is relevant and its processing is necessary and lawful, we will identify both an appropriate lawful basis and an additional condition required for processing special category data.

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We apply additional safeguards where appropriate and will not request or use sensitive information unnecessarily.

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Information relating to criminal convictions or offences will only be processed where legally permitted and subject to appropriate safeguards.

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8. Confidentiality and Information Sharing

Nardo treats the confidentiality of candidate, client and commercial information as an important professional obligation.

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We may share personal information, where necessary and lawful, with:

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• Clients and prospective employers in connection with relevant search or advisory activities.

• Candidates and authorised representatives involved in a recruitment process.

• Professional service providers supporting our business operations.

• Technology, website hosting, communications, research and data management providers operating under appropriate arrangements.

• Legal, regulatory or public authorities where required or permitted by law.

• Other parties where disclosure is necessary, lawful and appropriately authorised.

 

We limit disclosures to information relevant to the purpose for which it is shared.

Where service providers process personal information on our behalf, we seek to ensure that appropriate contractual, confidentiality and security arrangements are in place.

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We do not disclose confidential candidate information indiscriminately or make identifiable candidate introductions without the candidate's prior agreement.

Information exchanged during a professional relationship must be handled in accordance with any additional confidentiality or contractual obligations applicable to that engagement.

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9. Business Communications and Marketing

We may contact individuals in their professional capacity where we identify a relevant business reason to establish communication.

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Such contact may concern executive search assignments, prospective leadership opportunities, consulting services or matters relevant to an individual's professional responsibilities.

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Where we process personal data for business development, we will identify an appropriate lawful basis and comply with applicable electronic marketing requirements.

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Communications will identify Nardo and provide an appropriate means of requesting that further direct marketing communications cease.

 

We will respect objections to direct marketing and maintain appropriate suppression records to avoid further unwanted contact.

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Where consent is legally required for a particular form of marketing, we will obtain it before sending the communication, unless another lawful exception applies.

 

You may object to direct marketing at any time by contacting us using the details provided in this policy.

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10. Cookies and Website Technologies

Our website may use cookies and similar technologies to support essential functionality, maintain security, remember user preferences and understand website performance.

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Some technologies are necessary for the operation of the website. Others, including certain analytics or marketing technologies, may require your consent or be subject to specific statutory exceptions and objection rights.

Where consent is required, we will seek it before enabling the relevant technologies.

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Where an applicable exception permits the use of a technology without consent, we will comply with the conditions of that exception, including providing an appropriate means of objection where required.

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You can manage applicable preferences through our website's cookie controls and through your browser settings.

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Further information about the technologies in use, their purposes, providers and applicable retention periods will be made available through our cookie information and preference controls.

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11. Data Security

We take appropriate technical and organisational measures designed to protect personal information from accidental loss, unauthorised access, misuse, alteration or disclosure.

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Depending on the nature of the information and the systems involved, these measures may include access controls, authentication arrangements, secure storage, appropriate contractual safeguards, restricted information sharing and procedures for managing information security incidents.

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Access to confidential candidate and client information is restricted to individuals who have a legitimate business need to access it.

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No system of electronic transmission or storage can guarantee absolute security. However, we take data security seriously and review the protections we use in proportion to the risks involved.

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Where a personal data breach occurs, we will investigate and take appropriate action, including notifying relevant authorities or affected individuals where legally required.

12. International Data Transfers

Nardo's activities may involve professional relationships, candidates, clients and service providers located outside the United Kingdom.

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Where personal information is transferred internationally, we will assess the applicable legal requirements and ensure that any restricted transfer is supported by a valid transfer mechanism.

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Depending on the circumstances, this may include reliance on UK adequacy regulations, recognised contractual safeguards or another legally permitted transfer mechanism.

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We will apply appropriate safeguards to international disclosures, taking account of the destination, the recipient and the nature of the information involved.

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13. Data Retention

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including any applicable legal, regulatory, contractual or legitimate business requirements.

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Retention periods may vary according to the category of information, the nature of our relationship, the relevance of the information to ongoing activities and any applicable legal obligations.

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Our intended retention approach is as follows:

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• Candidate information: Ordinarily reviewed and retained for no longer than 24 months following the last meaningful professional interaction or relevant recruitment activity, unless a longer period is justified and lawful.

• Business development contacts: Ordinarily reviewed after 24 months without meaningful professional interaction or other continuing justification.

• Client and contractual records: Retained for the period reasonably necessary to meet contractual, accounting, legal and regulatory requirements, which may extend to six years or longer where justified.

• Website and technical information: Retained according to the relevant operational purpose, configured retention settings and applicable legal requirements.

• Marketing objections: Limited information may be retained where necessary to ensure that an objection or unsubscribe request continues to be respected.

 

Where information is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it.

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A request for deletion will be considered in accordance with applicable legal rights and any lawful grounds for continued retention.

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14. Your Data Protection Rights

Subject to applicable law and any relevant exemptions, you may have the right to:

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• Request access to personal information held about you.

• Request correction of inaccurate or incomplete information.

• Request deletion of personal information in certain circumstances.

• Request restriction of processing.

• Object to processing based on legitimate interests.

• Object to direct marketing at any time.

• Request the transfer of certain personal information to yourself or another organisation.

• Withdraw consent where processing relies on consent.

• Exercise rights relating to certain automated decision-making activities.

 

We aim to respond to valid rights requests within the statutory timescales and will inform you where a lawful extension or exemption applies.

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We may request proportionate information to verify your identity before responding to a request involving personal information.

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To exercise your rights, please contact us using the details in Section 19.

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15. Research, Technology and Human Judgement

We may use professional research platforms and technology-assisted tools to support information gathering, market analysis, document preparation and the administration of our services.

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We recognise that technology-generated information may be incomplete, inaccurate or outdated. Accordingly, information relevant to professional assessments and candidate representation should be subject to appropriate human review and verification.

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We do not intend to make recruitment or leadership suitability decisions producing legal or similarly significant effects solely through automated processing.

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Where technology providers process personal information on our behalf, we assess the appropriateness of their use and the safeguards applicable to that processing.

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16. Third-Party Websites and Services

Our website may contain links to third-party websites, professional networking services and other external platforms.

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We do not control the privacy practices or content of independently operated websites.

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We encourage visitors to review the relevant privacy notices before providing personal information to third parties.

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17. Data Protection Complaints

We take concerns about the handling of personal information seriously.

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If you believe that we have processed your personal information incorrectly, or that your data protection rights have not been respected, you may submit a complaint using the contact details below.

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We will acknowledge data protection complaints within 30 days of receipt, investigate them appropriately and keep complainants informed of progress and outcomes in accordance with applicable law.

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You also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK's independent data protection regulator.

Information Commissioner's Office
Website: https://ico.org.uk
Telephone: 0303 123 1113

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Where another data protection regulator has jurisdiction, you may also have the right to complain to that authority.

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18. Changes to This Privacy Policy

We may amend this Privacy Policy to reflect changes in our services, business operations, technology, legal obligations or data protection practices.

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The current version will be published on our website, together with the date of its most recent update.

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Where material changes affect how personal information is processed, we will provide additional notice or obtain consent where legally required.

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19. Contact Us

For questions concerning this Privacy Policy, requests relating to your personal information or complaints about our data protection practices, please contact:

Nardo Capital Consulting
Nardo Capital Ltd

 85 Priory Road Kenilworth

CV8 1LQ

United Kingdom

info@nardocapital-consulting.com

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We welcome enquiries concerning the confidentiality, accuracy, retention and lawful use of personal information in connection with our services.