Privacy Policy

Last updated: May 2026

Focus Cloud Group Ltd

Website: www.focuscloudgroup.org

Who are we?

Focus Cloud Group Ltd ("we", "us", "our") is a specialist recruitment and consulting company. We provide permanent and temporary/contract recruitment services to clients looking to recruit personnel for their businesses, as well as Workday Consulting and Application Management Services (AMS).

Registered address: 1 St. Katharine’s Way, London, UK, E1W 1UN

Data enquiries: gdpr@focuscloud.org

Telephone: +44 (0)20 3800 0785

We are registered with the Information Commissioner's Office (ICO) as a data controller. Our ICO registration number is ZB334675.

What does this Policy cover?

We at Focus Cloud Group Ltd take your personal data seriously. This policy:

- Sets out the types of personal data that we collect about you

- Explains how and why we collect and use your personal data

- Explains how long we keep your personal data for

- Explains when, why and with whom we will share your personal data

- Sets out the legal basis we have for using your personal data

- Explains the effect of refusing to provide the personal data requested

- Explains the different rights and choices you have when it comes to your personal data

- Explains how we may contact you and how you can contact us

This policy applies to candidates, contractors, clients, referees, and visitors to our website.

What personal data do we collect about you?

We collect the information necessary to be able to find available opportunities and to assess your eligibility through the different stages of recruitment. This information includes CVs, identification documents, educational records, work history, employment preferences, salary/rates, and references.

When you visit our website, we may also collect data about your visit, including pages viewed, time spent on the site, and information about the device and browser you are using. Where you have consented to analytics or marketing cookies, this data may be used to understand how our website is used and to support our marketing activity.

We do not routinely collect sensitive personal data or special category data about you. If, however, there is a legal basis for collecting sensitive personal data or special category data, or you volunteer this data, we will further process this data only where you have given your explicit consent.

Where do we collect personal data about you from?

The following are the different sources we may collect personal data about you from:

Directly from you - information you provide while searching for a new opportunity and/or during the different recruitment stages.

From an agent or third party acting on your behalf - for example, a Contractors Limited Company.

Through publicly available sources - including:

   - LinkedIn

   - Job boards

  - Other public sources such as Hunted, Facebook, Instagram, technology ecosystem community events, meetings, and personal introductions

By reference or word of mouth - for example, you may be recommended by a friend, a former employer, a former colleague, or a present employer.

Through our website - where you have consented to the use of analytics and marketing cookies, we collect data about how you interact with our website. We also use ZoomInfo WebSights, a B2B intelligence tool that may identify the company associated with a website visit based on IP address and firmographic data. This is used for legitimate business development purposes and does not identify individuals directly.

Where we collect your information through publicly available sources, we may do this with the aid of software programmes such as Hunted and Lusha. These programmes are given parameters on the requirements of a role and search through publicly available sources to find suitable candidates. They are designed to only output information on candidates that meet the search criteria. The parameters are restricted to searching for name, availability, and job role from public sites where there is a reasonable expectation that such information may be collected and further processed by recruiters for the purpose of sourcing candidates.

We also use artificial intelligence tools to support our internal operations, including Microsoft 365 Copilot and Autometry. Where these tools process personal data in the course of supporting our workflows, we ensure appropriate contractual safeguards are in place with those providers.

How do we use your personal data?

We use your personal data to:

- Match your skills, experience, and education with a potential employer or consulting engagement

- Contact you regarding relevant roles and next steps

- Submit your profile to clients, with your knowledge, where you are a suitable candidate

- Carry out verification checks such as referencing and identity confirmation

- Understand how our website is used and improve user experience

- Support our business development and marketing activities

- Comply with our legal and regulatory obligations

We will initially collect basic information - contact details, job role, and experience. We then pass on your name, job role, and experience to the client in search of personnel. If you are chosen by the client and progress to the next stage, we will collect more detailed information from you at the interview or equivalent stage and onwards in that manner.

How long do we keep your personal data for?

We retain your information for as long as is necessary for us to use it as described above, or to comply with our legal obligations and our legitimate business interests. We may retain some of your information after you cease to use our services, for instance, where this is necessary to meet our legal obligations, such as retaining information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including:

a. Our contractual obligations and rights in relation to the information involved

b. Legal obligations under applicable law to retain data for a certain period of time

c. Our legitimate interest in specialising in the relevant technology ecosystem skilled talent community

d. Statute of limitations under applicable law(s)

e. Potential disputes

f. If you have made a request to have your information deleted

g. Guidelines issued by relevant data protection authorities

Otherwise, we securely erase your information once it is no longer needed.

Who do we share your personal data with?

We share your personal data only where necessary and appropriate. This includes:

Client organisations - we share your personal data with the client who has a position to fill, in order to determine whether you are a good fit for the available position. Our clients are part of relevant technology ecosystem communities and we recruit for systems projects covering all sectors in the UK, Europe, and North America.

Third-party verification services - we may conduct checks to verify information you have provided, for example referencing, CreditSafe, and VIES. In such cases, we do not share your information with third parties beyond what is needed for verification purposes.

Technology platform providers - we store and process your personal data using the following platforms:

   - Bullhorn (recruitment CRM)

   - ETZ (contractor management and payroll)

   - Workday (HR and consulting services management)

   - Xero (accounting)

  - Microsoft 365 (email, documents, and collaboration)

Website analytics and performance providers - when you visit our website and accept the relevant cookies, data about your visit may be shared with the following providers:

   - Google LLC (Google Analytics 4 and Google Tag Manager) — for website analytics and tag management

   - Microsoft Corporation (Microsoft Clarity) — for website behaviour analytics including session recording and heatmapping

  - LinkedIn Ireland Unlimited Company (LinkedIn Insight Tag) — for marketing analytics and campaign measurement

Website intelligence providers - we use ZoomInfo Technologies LLC (ZoomInfo WebSights) to identify the companies visiting our website based on IP address and firmographic data, for the purpose of business development. ZoomInfo does not identify individuals directly; it identifies organisations. ZoomInfo's privacy policy is available at zoominfo.com/legal/privacy-policy.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

We do not sell your personal data to any third party.

International Data Transfers

Our primary recruitment and operational platforms (Bullhorn, ETZ, Workday, Xero, and Microsoft 365) store your personal data in data centres located within the United Kingdom or European Economic Area. We do not routinely transfer your personal data outside the UK in the course of our day-to-day operations.

In the event that any data is processed or accessed outside the UK by these providers, for example, for support or maintenance purposes, we rely on the contractual safeguards and standard data protection terms provided by those platforms, which are designed to meet UK GDPR requirements.

The following website tools are operated by companies headquartered outside the UK and may process data internationally:

   - Google LLC (USA) — Google Analytics 4 and Google Tag Manager

   - Microsoft Corporation (USA) — Microsoft Clarity

   - LinkedIn Ireland Unlimited Company (Ireland / USA) — LinkedIn Insight Tag

  - ZoomInfo Technologies LLC (USA) — ZoomInfo WebSights

Each of these providers operates under appropriate data transfer mechanisms, including Standard Contractual Clauses or UK adequacy arrangements, to ensure that any international processing meets UK GDPR requirements.

If you would like further information about the safeguards in place, please contact us using the details below.

What legal basis do we have for using your information?

For prospective candidates, contractors, referees, and clients, our processing is necessary for our legitimate interests in that we need the information in order to assess suitability for potential roles, to find potential candidates, and to contact clients and referees. The use of ZoomInfo WebSights to identify company visitors to our website is also based on our legitimate interest in business development.

If you are interviewed and submitted as a candidate, this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your explicit consent before undertaking such processing.

For clients, we may also rely on our processing being necessary to perform a contract with you, for example in contacting you.

Consent - where we place non-essential cookies on your device or process your data for purposes beyond the above, we will seek your explicit consent beforehand.

Do we use tools that assess or score candidates?

We use software tools that may generate match scores or rankings to help our consultants identify candidates who could be a good fit for a role. These tools are used to assist and inform our consultants; they do not make decisions about you.

A qualified member of our team always reviews the output of these tools and applies their own professional judgement before any candidate is progressed, shortlisted, or rejected. No decision that significantly affects you is made solely on the basis of an automated score or ranking.

If you have any questions about how our tools are used in relation to your application, please contact us using the details below.

What happens if you do not provide us with the information we request?

If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.

Cookies

To provide a better service to you on our website, we use cookies to collect data about how you browse. Please see our Cookie Policy at www.focuscloudgroup.org/cookie-policy for full details of how we use cookies and how you can manage your preferences.

What security measures do we take?

We have adopted appropriate security features in order to protect and keep secure personal information from loss, misuse, alteration, or destruction. We regularly review our security and encryption technologies and strive to protect personal information to the highest level possible.

SSL Technology

We employ Secure Sockets Layer (SSL) technology whenever any transaction is completed over our site. Transactions involving the passage of personal information occur in one of our secure online areas only. SSL technology encrypts the information you send through our site. The use of SSL technology requires two components:

   - An SSL-compatible browser; and

  - A web server to perform a key-exchange that establishes a secure connection.

For you to benefit from the SSL technology we have implemented:

   - You will need a browser with SSL capabilities. The latest versions of commonly used web browsers generally have this capability. However, it is your responsibility to check that this is the case. If you do not already have a browser with SSL capabilities, you can download one from a vendor's website.

  - You will also need an internet service provider that enables SSL technology. Nearly all internet service providers automatically enable SSL technology, but you will need to ensure this is the case with your provider.

Focus Cloud Group Ltd and its website manager make no warranty or representation in respect of the strength or effectiveness of the encryption capabilities of SSL technology and are not responsible in any way for events arising from any unauthorised access to the information you provide.

Your Rights

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.

The right to be informed

You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this policy.

The right of access

You have the right to obtain access to your information (if we are processing it), and certain other information similar to that provided in this Privacy Policy. This is so you are aware and can check that we are using your information in accordance with data protection law.

The right to rectification

You are entitled to have your information corrected if it is inaccurate or incomplete.

The right to erasure

Also known as the 'right to be forgotten', this enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

You have the right to 'block' or suppress further use of your information. When processing is restricted, we can still store your information but may not use it further. We keep lists of people who have asked for further use of their information to be blocked to make sure the restriction is respected in future.

The right to data portability

You have the right to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy, or transfer your information easily between our IT systems and theirs, safely and securely, without affecting its usability.

The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (i.e., if you no longer want to be contacted with potential opportunities). You may also object to ZoomInfo's processing of company data associated with your IP address via ZoomInfo's opt-out facility at zoominfo.com/legal/privacy-policy.

The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator. In the UK, this is the Information Commissioner's Office (ICO):

Website: www.ico.org.uk

Telephone: 0303 123 1113

The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time. Withdrawing consent does not mean that anything we have done with your personal data with your consent up to that point is unlawful. This includes your right to withdraw consent to us using your personal data for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs for baseless, excessive, or repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

How will we contact you?

We may contact you by phone, email, or post. If you prefer a particular contact method, please let us know.

How can you contact us?

If you are unhappy with how we have handled your information, or have further questions on the processing of your personal data, please contact us:

Focus Cloud Group Ltd

1 St. Katharine's Way

London

E1W 1UN

Email: gdpr@focuscloud.org

Telephone: +44 (0)20 3800 0785


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