WATTS ASSOCIATES PRIVACY NOTICE

Who is the data controller?

Name: Watts & Associates Recruitment Limited

Address: 15 Clarence Road, Southend-On-Sea, England, SS1 1AN

2. From what sources do we collect your data?

Data you provide to us directly

When you register on our websites/platforms or click on a job advertisement to fill out an application, you provide us with your data directly and voluntarily. When you respond to our cold outreach, you may submit additional details about yourself.

Data we automatically collect about you

We use automated tools such as web-scraping technologies to collect personal data from a range of professional and publicly available sources. This may include professional networking platforms such as LinkedIn, corporate websites, job boards, public directories, and other commercially available data sources. We also use technology-enabled tools to identify and consolidate publicly available personal data.

Additionally, we record and transcribe calls with you unless you opt out of recording and subsequent use of such data.

Data provided by third parties

As addressed in section 7 of this Privacy Notice, we obtain personal data of individuals and legal entities from third-party data suppliers such as Leopard List, ZoomInfo, A. I tools, and our affiliated company, We Are Revolution Ltd.

3. What types of personal data may we collect about you?

Personal & Contact Information: Full name, address, phone number, email; Date of birth/age; National ID or passport details (for right-to-work checks); Photo (sometimes)

Voice recordings and transcriptions: When we have a call with you, we record the call and transcribe its content.

Business Data: Your business email address, the organisation you are affiliated with, and your role.

Professional Background: CV/resume (work history, job titles, employers, dates), other data submitted by the candidates

Job Search Preferences: Desired role, industry, location; Salary expectations; Availability/notice period; Full-time vs. part-time, remote preferences; Willingness to relocate or travel

Assessment & Screening Data: Data concerning assessments completed by candidates.

Sensitive / Special Category Data: Ethnicity, gender, disability status — for diversity monitoring; Criminal record checks (DBS/background checks); Right-to-work status/visa/immigration information; Health information relevant to role adjustments

Communications: Emails, messages, and notes exchanged with recruiters

Third-Party / Sourced Data: Information from LinkedIn or other social profiles; Public professional information scraped or imported; Referral source data

Attorney Profiles: Detailed information including current title, practice areas, educational background, firm history, bar admissions, and contact details

4. For what purposes do we collect and process your data?

We collect, process, use, and share your personal data for the following purposes:

To promote our talent sourcing services to businesses via social media outreach, email marketing, SMS, cold-calling.

To scrape your personal data from publicly available third-party sources such as LinkedIn, company websites, and A.I-assisted tools to send you direct marketing emails/messages, and to build a candidate profile.

To connect candidates with organisations

To retain information relevant to the provision of our services when we record and transcribe the calls

To submit individual applicants’ information to specific businesses,

To brief candidates on specific roles,

To conduct individual consultant outreach,

To send promotional LinkedIn messages and emails to both job candidates on a one-to-one basis,

To share your data with our affiliated company, We Are Revolution Ltd.

To enrich your profile data by combining it with data we obtain from third-party sources such as publicly available information, A.I-assisted tools, and data suppliers.

While we use automated tools to assist with candidate identification, profiling, and matching, these tools support human decision-making but do not determine outcomes without human review.

5. What legal bases do we rely on to process your data?

We process personal data on the basis of our legitimate interests in operating a recruitment and talent sourcing business, including identifying suitable candidates, matching professionals with employment opportunities, and providing recruitment services to clients.

Our legitimate interests assessment (LIA) is available upon request.

When we collect and process your sensitive data, we also rely on one of the appropriate conditions under Article 9 of the UK GDPR.

When we collect data about you from Leopard Solutions Ltd, or scrape your data from LinkedIn, we rely on legitimate interests under Article 6.1.f of the UK GDPR.

6. Sharing your personal data with We Are Revolution Ltd

In accordance with Article 6(1)(f) UK GDPR, we process your personal data on the basis of our legitimate interests in sharing your details with We Are Revolution Ltd, a member of our group of companies, for the purposes of contacting you with information about our talent sourcing and recruitment services, including relevant job opportunities and related promotional communications.

7. Data we collect from third parties

We obtain the following types of personal data from third-party data supplier Leopard Solutions Ltd:

Attorney Profiles: Detailed information including current title, practice areas, educational background, firm history, bar admissions, and real-time contact details.

We may use this data to send you promotional LinkedIn and email messages about job opportunities and our talent sourcing services.

We may use third-party data suppliers such as ZoomInfo to collect additional data about you for the purposes of serving you more relevant job opportunities and to connect you with more relevant organisations.

We may use a third-party A. I-assisted tools to collect additional data about you for the purposes of serving you with more relevant job opportunities and to connect you with more relevant organisations. Such data may include publicly available data we scrape from your social media page and your affiliated organisation’s website and social media pages.

8. Data security

We establish and implement appropriate data security measures to ensure the availability, integrity, and confidentiality of your data. You may contact us to learn more about the specific data security measures we implement.

9. Data retention

We retain your personal data for so long as it is strictly necessary for the purpose for which it is collected and processed. When determining the applicable data retention period, we take into account various criteria such as statutory requirements, sensitivity of data, our legitimate interests, and your rights and legitimate expectations.

10. International data transfers

Where we transfer your personal data outside the United Kingdom, we ensure that appropriate safeguards are in place to protect your data. This is done either on the basis of an adequacy decision issued by the UK government, confirming that the destination country provides an adequate level of data protection, or by relying on one or more appropriate safeguards recognised under Article 46 of the UK GDPR.

These safeguards may include, where applicable, the use of standard contractual clauses approved by the UK authorities.

11. Your rights

Under the UK GDPR, individuals have a number of rights in relation to their personal data, including the following:

Right of access: You may request confirmation as to whether we process your personal data and obtain a copy of the personal data we hold about you.
Right to rectification: You may ask us to correct or update any personal data that is inaccurate or incomplete.
Right to object: You may object to our processing of your personal data where we rely on legitimate interests as the legal basis for processing.
Right to erasure (“right to be forgotten”): In certain circumstances permitted by law, you may request that we delete your personal data.
Right to data portability: You may request that we provide your personal data to you or transmit it directly to another organisation, where technically feasible.
Right to restriction of processing: You may ask us to limit how we use your personal data, for example, where you dispute its accuracy or object to its use.
Right to lodge a complaint with the data controller: Under the UK GDPR, you have the right to raise concerns or complaints with the data controller.
Rights in relation to automated decision-making and profiling: Where applicable, you have the right not to be subject to decisions based solely on automated processing, including profiling, where such decisions produce legal or similarly significant effects, except where such processing is legally permitted.

12. CCPA and US state laws - Privacy Notice

If the CCPA or another US-state privacy law applies to the collection and processing of your data, you may exercise the following rights:

The CCPA provides California residents with the following rights with respect to their Personal Information:

The Right to Know what Personal Information we collected, used, and disclosed about you

The Right to Delete Personal Information

The Right to Opt-Out if we sell or share your Personal Information

The Right to Limit Use or Disclosure of Sensitive Personal Information by us

The Right Not to Receive Discriminatory Treatment by us when you exercise any of your CCPA privacy rights.

We do not sell personal information in the conventional sense; however, we may share personal information for recruitment and business development purposes.

13. How to exercise your rights

You may exercise your rights by contacting us via email at info@watts-legal.com

14. Your right to file a complaint with the data protection authority

Under the UK GDPR and EU GDPR, you have the right to raise a complaint with the appropriate data protection supervisory authority.

If you are located in the United Kingdom, you may contact the Information Commissioner’s Office (ICO) to report concerns about how your personal data is handled, including via its website: https://ico.org.uk.

If you are located within the European Union, you can consult a list of national data protection authorities and their contact details here: https://iapp.org/resources/global-privacy-directory.