Privacy Policy

At James Associates, we are serious about GDPR and the way we handle your personal data.

This policy explains what we do with your personal information, why we want to use it, how we protect it, and what rights you have to control our use of your personal data.

The most important fact is that it’s your personal data. We have complete respect for your rights and would like to reassure you that we will only use it where necessary to deliver our services to you.

Information about James Associates

The registered address for James Associates is B2, Birdineye Farm, Birdineye Hill, Uckfield, TN22 5HA. Our Company Registration Number is 6660213.

We are a registered data controller with the Information Commissioners Office.

Our data protection registration number is ZA807245.

If you wish to contact us about any of the points in this policy or require any information about how we protect your privacy, please email us at We use this email address for all data protection and matters of data access.

The Purpose & Lawful Basis for Processing your Personal Data

We use information for different purposes, and each of these has a different lawful basis. As such, we are required by law to explain this to you.


If you have applied for a role via James Associates, we hold your personal details to process your application, and as such, we believe we have a lawful basis for holding this information.

When you apply for a client’s role via one of the job boards we use, your personal data enters our bespoke Applicant Tracking System (ATS), which keeps the data from all of our recruitment projects separate. The ATS is a cloud-based system provided by Smart Recruit Online whose own Privacy Policy can be viewed here:

We promise to share your data only with the specific client to whom you have applied.

Smart Recruit Online will invite you to join their candidate portal where you can manage your applications, personal data, update your CV and potentially apply to other client advertised roles.

You will have the opportunity to be forgotten or can opt-out of any receiving communication at any time.

If you are unsuccessful at the applicant stage, you will receive a rejection letter and can opt to delete your data.

If you are an active candidate (someone who we want to progress within the recruitment process), your details will be shared only with the client company to whom you have applied. This information will include your contact details, application form, CV and any telephone or video interview notes that have been generated. We aim to share as little as necessary, and only information relevant to the position for which you have applied.

If you are the successful candidate in one of our recruitment projects, you will be treated in the same way as our active candidates.


If you are an existing James Associates client, we hold your name and contact details because we have a contractual obligation to deliver services to you. We need your contact details to provide our services (such as to send you candidate and interview details, send you invoices and so on). We will hold your information for six years from the date of our last recruitment project with you for legal records.

When James Associates acts on your behalf for recruitment, you can be assured that we have robust procedures in place to comply with GDPR in terms of dealing with both your company’s data and that of the candidates we process for you.

We store all our client information on a secure Customer Relationship Management System (CRM), including all relevant contact details (names, addresses, email addresses, mobile phone numbers and landlines), and records of conversations and actions relating to potential and active recruitment projects. The CRM is a cloud-based system provided by Apricot Recruitment Software, and their privacy policy can be viewed here

This information is treated with the utmost confidentiality and will not be shared with candidates without prior permission. This data will be stored on the CRM for as long as it remains relevant to our relationship with the client unless we receive written notice that the client no longer wishes that we retain it.

Any communication between James Associates and our clients, which is stored within our email system, will be deleted on a regular ongoing basis in line with our internal administration policies.

Whilst dealing with candidates on your behalf, we will treat the retention of their personal information as detailed in the above section, to comply fully with GDPR.

All our clients are offered access to the ATS in order to view applicant information, and where clients have access to personal data about candidates, we assume that they too have robust systems in place to comply with GDPR.

If you are a previous James Associates customer, in the six-year period following the end of our last recruitment project, we may continue to contact you with information about our services because we think you will find it useful. We believe we have a legitimate interest in this direct marketing activity (and this is also permitted under the Privacy and Electronic Communications Regulations or ‘PECR’). Still, you are always able to unsubscribe by clicking the link at the bottom of the emails we send, or by emailing us at

If you’re not an existing customer, we may have your contact details on our marketing list so we can contact you about our services. You may withdraw consent at any time – usually, this is easiest by choosing the ‘unsubscribe’ option at the bottom of information we send to you. You can also email us at at any time.

Please note that if you do this, we will delete your records on our marketing list. If you remain on our marketing list, we will hold your information for two years from the time we last checked that you wanted to receive communication from us.


If you are an employee of (or temporary or contract worker at) James Associates, we hold your personal details for remuneration, taxation, pension and benefits purposes. We have a legitimate interest in being able to use your information in this way, and we also believe it’s in your interests to show that you’re up to date with data protection training. We will hold your personal information for six years from the expiry of your employment with James Associates for legal records.


If you are a supplier or other business associated with James Associates, we will hold your contact details because we have a legitimate interest in doing business with your company. We will aim to hold this information for three years since we were last in contact with you. It’s possible we picked this information up from public directories (such as LinkedIn and internet searches) or that you passed your details to us with a business card.

Who Receives your Personal Data?

If you are a candidate and have applied for a role via a job board, your personal data will be received by the job board company, and then by Smart Recruit Online Ltd, who feed the information into our applicant tracking system (ATS). These companies act as data processors for us. Where applicable, your personal data will be passed onto our clients if you are selected as a suitable candidate for one of their vacancies. Occasionally, your details may be relevant for a vacancy for which you have not applied. If this is the case, we will always seek your permission before sharing your personal data with another client for your mutual benefit.

If you are a client, we hold your contact details on our accounting system (QuickBooks) and on CRM support systems (Apricot and Mailchimp). These companies are data processors for us.

If you are an employee of James Associates, your personal data will be passed to HMRC for tax purposes, and to our payroll and pension providers for your personal benefit and remuneration.

Your Personal Data Rights

The personal data we hold about you is your data, so you have certain rights over them. This section summarises your rights. You can exercise any or all these rights when you choose, and the easiest way is by dropping us an email at

Where we are processing your data based on your consent (e.g. for a job application), you can withdraw that consent, and we must immediately stop processing your data. Please note that up to that point, we’re acting lawfully with your consent, and withdrawal of consent cannot be backdated.

You have the right to request a copy of all personal data we hold relating to you, and we must provide this within 30 days. You also have the right to require us to correct any wrong records.

You have the right to require us to erase personal data, and we must comply with this right. We retain the right to keep data that is needed to establish, exercise or defend a legal claim.

Where we process your data based on a ‘legitimate interest’ (underlined in the section on purpose and lawful basis, above), you still have the right to object to our processing of that data. From that point, we must stop processing your data until we have determined whether your rights override our interests.

Finally, you have the right to have your personal data transferred to another organisation, and we’re obliged to provide it to you in a clear and reasonable format.

The personal data we hold about you is your data, so you have certain rights over them. This section summarises your rights. You can exercise any or all these rights when you choose, and the easiest way is by dropping us an email at

Your Rights to Lodge a Complaint with Regulator  

At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. Please refer to the ICO at

Of course, we hope that we can resolve your issue quickly and fairly – you can contact us at

Our Contractual Requirements to Use your Personal Data

If you are a candidate, we have a legitimate interest in using your personal data for the purposes of processing your job application and sharing it with potential employers.

If you’re a James Associates client, it’s a requirement that we collect personal information from you so that we can enter into a contract with your company.

If you’re an employee (or temporary or contract worker) at James Associates, we have a legitimate interest in using your personal data for payroll, taxation, pension and benefits purposes. We use our legitimate interests as the lawful basis for processing your data (which is why we don’t ask for your consent to process it).

Automated Processing of your Personal Data

The only automated processing we do of personal data is to take information provided to the job boards by candidates who apply for advertised roles and move it into our applicant tracking system (ATS).

We also use Mailchimp and Apricot to undertake some automated communications activities. You are able to manage the information you receive from us through these channels at any time.

Other Purposes for Processing Personal Data

We don’t process your personal data for any other purpose than we’ve described here. We won’t sell your personal data to other companies.

As we develop the James Associates range of products, we might add a new data process to our platform that uses your personal information. Should we decide that we want to develop a new processing purpose, we will contact you to let you know what we intend to do, the lawful basis we will use, and your rights over our intended new processing. We will also publish information about it here.

How to Contact Us

If you have any questions, concerns or just want some more information about our privacy management, drop us a line at