Privacy Policy

FWB Executive Search Limited

Last updated: October 2026

1. Introduction

FWB Executive Search Limited (“FWB”, “we”, “us” or “our”) is an executive search and recruitment consultancy specialising in senior management, executive and board-level appointments.

We also deliver professional development programmes, leadership events and professional networks, including activities undertaken in partnership with other organisations.

We are committed to protecting your personal information and respecting your privacy. This Privacy Policy explains how we collect, use, store, share and protect personal data when you engage with our services.

We process personal information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, as amended, and other applicable UK data protection legislation, including relevant provisions of the Data (Use and Access) Act 2025.

Data Controller

FWB Executive Search Limited is the Data Controller for personal information collected and processed for our executive search, recruitment and business activities, except where another arrangement is expressly identified.

Our contact details are:

FWB Executive Search Limited
19 Alva Street
Edinburgh
EH2 4PH

Email: gdpr@fwbltd.com

2. How We Collect Personal Information

We collect personal information directly from individuals and, where appropriate, from third-party sources.

Information collected directly from you

We may collect information when you:

• Submit a CV or application through our website or another recruitment platform.
• Contact us regarding career opportunities.
• Participate in interviews, assessments or recruitment discussions.
• Communicate with our consultants by email, telephone, video call or in person.
• Attend our professional development programmes, events or networking activities.
• Register for newsletters or business communications.
• Engage with us as a candidate, client, supplier or business partner.

Information collected from third parties

As an executive search business, we proactively identify and research individuals who may be suitable for senior appointments.

We may collect professional information from:

• Publicly available professional profiles, including LinkedIn.
• Company websites, biographies and professional directories.
• Professional networks and industry publications.
• Clients, business contacts and professional referrals.
• Recruitment platforms and candidate databases.
• Referees and assessment providers, where appropriate.
• Third-party recruitment technology and professional data providers.

FWB also uses Loxo Source, which provides professional information collected from publicly available online sources and enriched through third-party data partners.

This may include professional contact information, employment history, qualifications and other publicly available career-related information.

We use this information to identify and contact individuals who may be suitable for relevant executive and senior-level appointments.

Where personal information is obtained indirectly, we will provide appropriate privacy information in accordance with our legal obligations, including details of the source or categories of sources where required.

3. What Personal Information We Collect

The personal information we collect depends on your relationship with FWB.

Candidates and prospective candidates

We may collect:

• Name, contact information and location.
• Current and previous employment information.
• Job title, professional experience and career history.
• Qualifications, professional memberships and education.
• CVs, biographies and professional profiles.
• Salary expectations and remuneration information.
• Career aspirations and preferences.
• Interview notes, assessment results and professional feedback.
• References and other relevant recruitment information.
• Correspondence and records of previous engagement with FWB.

Where necessary and legally permitted, we may also process special category information, including information relating to health, disability or diversity characteristics.

We will only process criminal conviction information where permitted by law and where appropriate safeguards are in place.

Clients and business contacts

We may collect names, job titles, business contact information, company details, correspondence and information relating to our professional relationship.

Suppliers and professional partners

We may collect contact details, business information, contractual records and financial information required to manage our commercial relationships.

Programme participants and event attendees

We may collect names, job titles, organisations, contact details, attendance records, programme participation information and relevant event preferences.

4. How We Use Your Personal Information

We collect and process personal information where it is necessary for an identified and lawful business purpose.

We may use personal information to:

• Identify and assess individuals for executive and senior-level appointments.
• Contact potential candidates regarding relevant career opportunities.
• Maintain professional relationships with candidates and business contacts.
• Manage recruitment assignments and candidate selection processes.
• Present suitable candidates to clients.
• Arrange interviews, assessments and appointments.
• Verify qualifications, experience and professional references.
• Maintain accurate and relevant recruitment records.
• Deliver leadership development programmes, professional networks and events.
• Manage client relationships and contractual obligations.
• Communicate relevant business information, subject to applicable marketing rules.
• Meet legal, regulatory and compliance obligations.
• Establish, exercise or defend legal claims.
• Maintain the security and effectiveness of our systems and services.

We will not use personal information for purposes that are incompatible with those for which it was originally collected unless permitted by law.

5. Our Legal Bases for Processing Personal Information

Under Article 6 of the UK GDPR, we must have a lawful basis for processing personal data.

Depending on the circumstances, we rely on the following:

Legitimate interests

Our legitimate interests include identifying suitable candidates for executive appointments, maintaining professional relationships, delivering recruitment services, developing our business and maintaining accurate professional records.

As an executive search consultancy, we may process publicly available professional information to identify individuals who could be suitable for management, executive and board-level opportunities.

Before relying on legitimate interests, we consider whether the processing is necessary and balance our interests against the rights, freedoms and reasonable expectations of individuals.

Contractual necessity

We may process personal information where necessary to enter into or perform a contract with an individual.

Legal obligations

We may process information to comply with legal, regulatory, tax, accounting and other statutory requirements.

Consent

Where required, we will seek your consent before processing personal information for particular purposes. You may withdraw consent at any time, without affecting processing already carried out lawfully.

Special category information

Where we process special category data, we will identify an appropriate additional condition under Article 9 of the UK GDPR and, where required, the Data Protection Act 2018.

6. Use of Loxo and Recruitment Technology

FWB uses Loxo, a Talent Intelligence Platform that combines recruitment, candidate sourcing and Customer Relationship Management (CRM) functionality within one system.

Loxo supports our executive search activities by enabling us to manage candidate and client information, identify potentially suitable individuals, maintain professional relationships and coordinate recruitment assignments.

Information held within Loxo may include:

• Names and professional contact details.
• Current and previous employment information.
• Education, qualifications and professional experience.
• CVs and professional profiles.
• Recruitment correspondence and activity records.
• Interview notes and assessment information.
• Other information relevant to recruitment assignments.

Candidate sourcing and data enrichment

Loxo Source provides professional information gathered from publicly available online sources and enriched through third-party data partners.

FWB may use this information to identify and contact individuals about relevant career opportunities, subject to applicable data protection requirements.

Data protection functionality

Loxo provides functionality designed to support compliance with data protection legislation, including tools for managing candidate consent, lawful bases for processing, data retention and individual data protection requests.

FWB determines the lawful purposes for which personal information is processed and remains responsible for ensuring that our use of Loxo complies with UK GDPR.

We take reasonable steps to ensure that information held within Loxo is relevant, accurate and appropriate for our recruitment activities.

Loxo operates using multi-region technology infrastructure. Personal information may be stored, accessed or processed across different geographical locations rather than within one fixed country. FWB remains responsible for ensuring that its use of Loxo complies with UK data protection legislation. Further information about international transfers is provided in Section 8.

Individuals may contact gdpr@fwbltd.com to exercise their data protection rights or request further information about how their personal information is processed.

7. Sharing Your Personal Information

We may share personal information with third parties where necessary to provide our services or fulfil our legal obligations.

These may include:

• Clients and prospective employers involved in recruitment assignments.
• Assessment and psychometric testing providers.
• Professional reference and verification providers.
• Technology, CRM and cloud service providers, including Loxo.
• Professional advisers, including legal and compliance advisers.
• Event, programme and professional network partners.
• Regulatory bodies, public authorities and law enforcement agencies where legally required.

We will only share personal information where there is an appropriate lawful basis.

Candidate information will be shared with prospective employers where appropriate for a recruitment assignment, taking account of confidentiality, transparency and the individual’s reasonable expectations.

We require third-party processors acting on our behalf to protect personal information through appropriate contractual and security arrangements.

8. International Transfers and Storage of Personal Information

Individuals may request further information about applicable international transfer safeguards by contacting gdpr@fwbltd.com.

Where required, FWB will assess transfer risks and implement appropriate additional safeguards. FWB assesses relevant contractual and security arrangements with its technology providers.

Depending on the destination and circumstances, a lawful transfer mechanism may include UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework where the recipient is appropriately certified), the UK International Data Transfer Agreement (IDTA), the UK Addendum to the European Commission Standard Contractual Clauses, or another mechanism permitted by law.

Where personal information is transferred internationally, FWB is responsible for ensuring that any restricted transfer complies with applicable UK data protection legislation, including the UK GDPR and the Data Protection Act 2018, as amended.

Loxo has informed FWB that it operates using multi-region infrastructure and does not restrict personal information to one fixed geographical storage location. Personal information processed through Loxo may therefore be stored, accessed or processed outside the United Kingdom.

FWB uses third-party technology providers, including Loxo, to support executive search, recruitment, customer relationship management and wider business activities.

9. How Long We Retain Personal Information

FWB retains personal information only for as long as necessary to fulfil the purposes for which it was collected, meet legal obligations and support legitimate business requirements.

Our retention arrangements are governed by our internal Data Retention Policy.

In relation to candidate and professional contact information, FWB periodically reviews records to identify information that is no longer relevant or necessary.

Our general retention approach is to delete candidate and professional contact records where there has been no meaningful professional engagement for eight years, unless continued retention is justified by an appropriate lawful purpose.

This eight-year retention period supports our executive search activities, recognising that senior-level career opportunities and professional relationships may develop over extended periods.

Other information, including contractual, financial, programme and legal records, may be retained for different periods depending on applicable requirements.

We periodically review information held within our recruitment systems, including Loxo, to identify records that are no longer relevant or necessary.

Loxo provides data management functionality that can support the administration of retention periods and data protection requests. FWB remains responsible for determining and applying its own retention requirements.

Where an individual requests that we stop contacting them, we may retain limited identifying information in a suppression record to prevent their details from being inadvertently reintroduced into our recruitment database.

10. Your Data Protection Rights

Under UK data protection legislation, individuals have a number of rights in relation to their personal information.

These include:

• Right of access: Request confirmation of whether we process your personal information and obtain a copy.
• Right to rectification: Request correction of inaccurate or incomplete information.
• Right to erasure: Request deletion of personal information in certain circumstances.
• Right to restrict processing: Request that we limit how personal information is used in certain circumstances.
• Right to data portability: Receive certain information in a structured, commonly used and machine-readable format where the legal requirements apply.
• Right to object: Object to processing based on legitimate interests, including executive search activities.
• Rights relating to automated decision-making: Exercise applicable rights concerning decisions made solely through automated processing that produce legal or similarly significant effects.
• Right to withdraw consent: Withdraw consent where consent is the lawful basis for processing.

These rights are not absolute and may be subject to legal exemptions.

Requests should be directed to gdpr@fwbltd.com.

We will respond without undue delay and normally within one calendar month, subject to applicable statutory rules and permitted extensions.

11. Requests to Stop Contact or Delete Personal Information

We recognise that individuals may not wish to be contacted regarding executive search opportunities.

You may request that FWB stops contacting you or removes personal information from our recruitment systems by emailing gdpr@fwbltd.com.

Where appropriate, we will delete your personal information from our active recruitment records.

We may retain the minimum information necessary to maintain a suppression record, ensuring that your details are not inadvertently collected again through publicly available professional sources or recruitment research.

This may include limited identifying information sufficient to prevent future contact.

Any retained suppression information will be restricted to the purpose of respecting your communication preferences and will not be used for recruitment approaches.

12. Call Recording and Transcription

FWB may record or transcribe telephone and virtual meetings where appropriate for legitimate business purposes.

These purposes may include:

• Maintaining accurate records of professional discussions.
• Supporting recruitment assignment delivery.
• Recording agreed actions and decisions.
• Improving service quality and internal training.

Where recording or transcription takes place, we will provide appropriate information and identify a lawful basis for processing.

Where consent is required, we will obtain it before proceeding.

Recordings and transcripts will be treated as confidential and access will be restricted to authorised individuals.

They will be stored securely and retained only for as long as necessary in accordance with our retention arrangements.

Individuals may exercise applicable data protection rights in relation to personal information contained in recordings or transcripts.

13. Professional Development Programmes and Networks

FWB delivers professional development programmes, leadership events and professional networks, sometimes in partnership with other organisations.

We may process personal information to:

• Administer programme applications and participation.
• Manage event registration and attendance.
• Communicate programme information and updates.
• Facilitate relevant professional networking activities.
• Manage programme partnerships and associated contractual obligations.
• Evaluate and improve programme delivery.

Where programmes are delivered jointly with other organisations, we will ensure that appropriate data protection arrangements are in place, including clarity over the respective responsibilities of participating organisations.

We will not share personal information for unrelated purposes without an appropriate lawful basis.

14. Marketing and Professional Communications

FWB may contact individuals with relevant information about executive search services, professional opportunities, events, programmes and business activities.

Communications will be managed in accordance with applicable data protection and electronic marketing legislation, including the Privacy and Electronic Communications Regulations (PECR).

Where consent is required, we will obtain it.

You may opt out of marketing communications at any time by using the unsubscribe facility where provided or contacting optout@fwbltd.com.

Opting out of marketing will not necessarily prevent communications required for an existing contractual or professional relationship.

15. Cookies and Website Analytics

Our website may use cookies and similar technologies to support website functionality, understand visitor interactions and improve our services.

These may include essential cookies and, where enabled, analytics or other optional cookies.

Where required by law, we will obtain consent before placing non-essential cookies on your device.

Further information about the cookies in use, their purposes and how preferences can be managed will be provided through our website’s cookie information and consent arrangements.

16. Data Security

FWB takes appropriate technical and organisational measures to protect personal information against unauthorised access, loss, alteration, disclosure or destruction.

These measures may include:

• Access controls and user permissions.
• Password protection and authentication measures.
• Secure cloud-based systems.
• Confidentiality obligations for employees and relevant third parties.
• Appropriate security arrangements with technology providers.
• Secure information sharing and document handling.
• Employee data protection and cybersecurity awareness.
• Procedures for identifying and responding to personal data breaches.

Access to personal information is limited to those who require it for legitimate business purposes.

Where personal information is processed by third-party providers, including Loxo, we require appropriate contractual and organisational safeguards to protect the information.

17. Automated Processing and Artificial Intelligence

FWB uses recruitment technology, including Loxo, which may incorporate artificial intelligence, automated matching and data enrichment functionality.

These tools may assist with identifying potential candidates, reviewing professional information and supporting recruitment research.

FWB remains responsible for ensuring that any personal information processed through these technologies is handled lawfully, fairly and transparently.

Technology-assisted candidate identification and matching do not replace the professional judgement of our executive search consultants.

FWB does not make recruitment decisions based solely on automated processing that produces legal or similarly significant effects, unless permitted by applicable law and accompanied by the required safeguards.

Individuals may contact gdpr@fwbltd.com for further information about the processing of their personal data.

18. Changes to This Privacy Policy

We review this Privacy Policy periodically to ensure it reflects our business activities, technology systems and applicable data protection requirements.

We may update the policy where necessary to reflect changes in legislation, regulatory guidance or the way we process personal information.

The most recent version will be made available through our website.

19. How to Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights or have concerns about how your information is processed, please contact:

FWB Executive Search Limited
GDPR
19 Alva Street
Edinburgh
EH2 4PH

Email: gdpr@fwbltd.com

We will review and respond to data protection enquiries and complaints in accordance with applicable legal requirements. If you have concerns about how FWB processes your personal information, please contact gdpr@fwbltd.com. We will acknowledge and investigate complaints and respond without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator, at www.ico.org.uk or 0303 123 1113.