Privacy Statement

Right to Object: You have a legal right to object at any time to:

(i) use of your personal information for direct marketing purposes; and

(ii) processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate ground for our continued processing.

1 Who We Are

Welcome to the Cartwheel Recruitment Limited (Cartwheel, us or we).

Cartwheel Management Recruitment is the trading name of Cartwheel Recruitment Limited (company number 05953639). Cartwheel respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

You are not obligated to provide your personal information to Cartwheel, however, as this information is required for us to provide you with our services we will not be able to offer all of our services without it.

We are the data controller and are registered on the Information Commissioner’s Office Register; registration number Z102005X. The person responsible for privacy issues is Hannah Horler whose contact details are available via our website.

Any complaint or query should be sent to Hannah Horler.

We do not transfer outside the European Economic Area or “profile” data subjects. This would involve decisions being made about you by automated means without human input.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Information That We Collect

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that we collect from is:

  • Name (inc. previous)
  • Date of Birth
  • Home Address
  • Personal Email
  • Home Telephone Number
  • Mobile Telephone Number
  • National Insurance Number
  • Passport Number
  • Driver’s License Number
  • Reference checks (both personal and work)
  • Photographs (if applicable)
  • Qualifications / Training
  • Travel history
  • Relationship status
  • Employment history
  • Address history
  • Special Category Data (i.e. details about religion, sexuality etc)

How is the Information collected?

We collect information in the below ways: –

  • Information we collect from you whether this is with you completing an application form; sending us your CV; registering online; corresponding and talking to us or by you attending interviews
  • Third parties or publicly available sources.We may receive personal data about you from various third parties such as jobs board. Linked in and other such websites, referees or colleagues who refer candidates to us
    • Technical Data from the following parties:

(a)    analytics providers [such as Google based outside the EU];

(b)    search information providers to vet the information we are provided with relating to you.

(c)    identity and contact data from publicly availably sources to vet your credentials.

2     How We Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Cartwheel takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice.

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To register you as a candidate Performance of a contract with youLegal obligation
1.     to enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts.2.

3.     to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs;

Performance of a contract with you
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Performance of a contract with you(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To transfer certain personal data to DBS Legal Obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To provide other ancillary services such as coaching Performance of a contract with you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To approach you with details of vacancies that we consider may be of interest to you Necessary for our legitimate interests (to develop our products/services and grow our business). The processing will be non intrusive and  you can opt out at any time.


Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us through the contact section of the Website.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Sharing and Disclosing Your Personal Information

Regulatory and Law Enforcement Agencies

As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under privacy laws and other laws, we may disclose certain personal information to such bodies or agencies.

New business owners

If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors.  If this happens, you will be sent notice of such event.


We disclose your personal information to clients who have vacancies for jobs in which you are interested.

Trusted Third Parties

We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:

  • employment reference checking;
  • qualification checking;
  • criminal reference checking (as required);
  • verification of details you have provided from third party sources; and/or
  • psychometric evaluations or skills tests.

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Cartwheel uses third-parties to provide services and business functions including payroll provision, CRM system, confidential waste, IT support and telephone providers.  All processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. Individual providers are available upon request.
Safeguarding Measures

Cartwheel takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: SSL Encryption, TLS Encryption, Restricted access to secure data, 2 Factor Authentication, Multi Layer Firewalls, Multi Anti Virus and Anti-Malware Protection, and password protection of database systems.

Use of Cookies

Like most websites, when you visit our sites we place cookies on your computer or other device.  For the most part, these cookies are used to enable the websites’ functionality, improve the user experience or help us to optimise our websites, measure traffic and other internal management purposes.

We run targeted and relevant banner advertising on a number of whitelisted websites around the world to present you with jobs and content that we believe will be of interest. We target these adverts based on your previous interactions with our website, with our emails and through your engagements with our consultants. Your interaction with our advertising may be used to measure the effectiveness of our advertising campaigns and to improve our marketing strategy in accordance with our legitimate interests. No advertising campaigns or advertising tracking technology records your personally identifiable information.

You can find out more about our use of cookies, including how to reject cookies, in our Cookie Policy here.

Cookies used in this website

We apply cookies on our Website. If you are not interested in the advantages of our cookies, the “Help” function of your browser can help you configure your browser to prevent cookies or delete existing cookies. Also, you can learn how to block all new cookies on your browser and which configuration steps are required to receive a notification about new cookies. Please see the following table for cookies that we currently use on our website:

Name of Cookie 1st or 3rd party Cookie? If 3rd party: Who is setting it? Purpose of the Cookie? What data holds the Cookie? Is it a session or persistent Cookie? If persistent, how long is its lifespan?
_ ga 3rd party – Used to distinguish users. different values persistent 2 years
_gid 3rd party – Related to Google analytics – Used to distinguish users different values persistent 2 years
 _utma  3rd party –  Related to Google analytics –persistent cookie  keeps track of the number of times a visitor has been to the site  persistent  2 years
  __utmb and __utmc   3rd party –  Related to Google analytics  calculate how long a visit takes persistent  2 years
 __utmz   3rd party –  Related to Google analytics  keeps track of where the visitor came from  persistent   2 years
 __cfduid  Cloudfare  Related to feefo  Idenfity client IP address and apply security settings per client basis persistent


Legitimate Interests

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate. 
We use the legitimate interests’ legal basis for processing your personal data which is collected via CVs and through starter information in the interests of providing our service. Our service to place candidates into work and supply clients with suitable employees. We are unable to conduct our business activity and fulfil our aims without this data.   

How Long We Keep Your Data

Cartwheel only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details, Payroll Information) for a minimum of 7 years after which time it will be destroyed.

We will also keep all other applicant information including CVs on file for 10  years after last contact. We do this because the nature of our business and the range of opportunities that we explore with our clients means that we need a variety of candidates to consider. This also means that you will have access to as wide range of future opportunities.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise or withdraw your consent.