Business Contact Privacy Notice
1. Who we are and who this notice covers
1.1 Sanctuary Search Ltd, trading as Sanctuary Graduates (we, us or our), provides early careers recruitment, attraction and related services. This notice explains how we use personal information about named business contacts, including people at organisations we may wish to work with. It applies to business development and marketing activity where we determine the purposes and means of processing.
1.2 Sanctuary Search Ltd is registered in England and Wales under company number 08013693. Our registered office is The Union Building, 51–59 Rose Lane, Norwich, NR1 1BY. We are the controller for the business contact processing described here.
1.3 This notice is separate from our candidate and applicant privacy information. It does not govern recruitment applications or assessments.
2. What information we use
2.1 We may hold your name, employer or organisation, professional role or job title, industry, work email address, business telephone number, professional profile information, business location and records of our communications with you. We may also keep information about the business services your organisation may require and your marketing preferences. We do not seek to collect sensitive personal information for B2B prospecting.
3. Where we get your information
3.1 We may obtain professional contact information from publicly accessible professional and business sources, from direct business interactions, referrals, and from business contact data providers, including Apollo.io. Apollo compiles contact information from a range of sources. We cannot assume that every item of information supplied by Apollo was obtained directly from a public website. If you ask, we will provide the source information available to us for your record.
4. Why we use it and our lawful basis
4.1 We use business contact information to identify organisations that may benefit from our recruitment services, select relevant professional contacts, introduce our services, respond to enquiries, arrange meetings, manage business relationships, maintain accurate records and respect marketing preferences.
4.2 For relevant B2B prospecting and business relationship management, we generally rely on legitimate interests under Article 6(1)(f) UK GDPR: our interest in developing our business and informing organisations about recruitment services that may be relevant to their needs. We consider the professional context, relevance of the communication, amount of information used and individuals’ rights and expectations. This basis does not override any applicable electronic marketing rules. Where a different lawful basis is required for a distinct activity, we will identify it.
5. How we contact you
5.1 We may contact relevant business representatives by professional email or telephone about recruitment services. We use Apollo.io to source and organise business contact information and Brevo to support outbound email communications. We aim to make our communications relevant to your professional responsibilities and provide a straightforward way to opt out of direct marketing.
6. Who receives your information
6.1 Access is limited to authorised Sanctuary personnel and service providers who need the information for business development, communications, security or administration. Our service providers for this activity include Apollo.io and Brevo, according to the services used. We may also share information with professional advisers, regulators or authorities where appropriate or required by law.
6.2 Service providers may process personal data on our behalf under applicable contractual arrangements. Where a provider acts for its own purposes, it may also be a controller for those activities; its own privacy information may apply.
7. International processing
7.1 Some service providers may process or access information outside the United Kingdom. Where Sanctuary makes a restricted international transfer, we use an applicable UK transfer mechanism and any other safeguards required by law. You may contact us for information about relevant transfer arrangements and safeguards for your information.
8. How long we keep information
8.1 We retain business prospect records only while they remain necessary for relevant business development or another legitimate purpose. Because early careers recruitment usually follows an annual buying cycle, we review prospect records after 24 months without meaningful engagement, representing two recruitment cycles. The 24-month point is a review trigger, not a guarantee that records will always be retained for that period. We may remove information earlier if it becomes outdated, irrelevant or unnecessary.
8.2 At review, we delete or anonymise information where no continuing purpose justifies its retention. Where you unsubscribe or object to direct marketing, we stop using your information for that purpose and may retain a minimal suppression record for as long as necessary to avoid contacting you again. We may retain relevant records for longer where necessary for complaints, regulatory matters or legal claims, subject to appropriate review.
9. Your rights and marketing choices
9.1 You may have rights to access, correct, erase or restrict personal data, to object to processing based on legitimate interests, and to complain to the Information Commissioner. Other rights may apply depending on the circumstances and lawful basis.
9.2 YOUR RIGHT TO OBJECT TO DIRECT MARKETING: You can object to our use of your personal information for direct marketing at any time. If you do, we will stop using it for that purpose. You can use the unsubscribe facility in our marketing emails or contact us directly. We may keep minimal information on a do-not-contact list so that we respect your choice.
10. Contact and complaints
10.1 For questions about this notice, to request source information or to exercise your rights, contact Andrew Neil at andrew.neil@sanctuarygraduates.co.uk. You may also write to Sanctuary Search Ltd at The Union Building, 51–59 Rose Lane, Norwich, NR1 1BY.
10.2 If you have a concern about our use of your information, please contact us so we can investigate. You also have the right to complain to the Information Commissioner’s Office at www.ico.org.uk.
11. Changes to this notice
11.1 We may update this notice to reflect changes in our activities, suppliers or applicable law. The current version and its effective date will be made available on our website. Where changes materially affect how we process your information, we will take steps to bring them to your attention where required.
