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Privacy Policy

Last Updated: June 2026

Introduction

Maxwell Stephens Limited ("Maxwell Stephens", "we", "us" or "our") is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect your personal information when you visit our website, engage with our recruitment services, apply for jobs, become a client, supplier, contractor, or otherwise interact with us.

We process personal data in accordance with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and other applicable data protection laws.

Please read this Privacy Policy carefully to understand how we handle your personal information.

Who We Are

Maxwell Stephens Limited

Golden Cross House

8 Duncannon Street

London

WC2N 4JF

Email: info@maxwellstephens.com

For the purposes of UK data protection legislation, Maxwell Stephens Limited (registered in England and Wales, company number 02660883; registered office: 43 Romanby Drive, Darlington DL3 8EJ) is the Data Controller responsible for your personal information.

Information We Collect

Depending on your relationship with us, we may collect and process the following information:

Candidate Information

  • Name
  • Contact details
  • CV and employment history
  • Qualifications and certifications
  • Professional memberships
  • Salary information and expectations
  • References
  • Interview notes
  • Right-to-work documentation
  • Identity verification information
  • Career preferences
  • Correspondence with us

Client Information

  • Name
  • Business contact details
  • Job titles
  • Recruitment requirements
  • Communications and meeting notes
  • Contractual and billing information

Supplier Information

  • Contact details
  • Company information
  • Banking and payment details
  • Contractual records

Website Information

When you visit our website we may collect:

  • IP address
  • Browser type
  • Device information
  • Website usage data
  • Referral source information
  • Cookie preferences
  • Analytics data

Special Category Data

Certain information may be classified as Special Category Data under UK GDPR, including information relating to:

  • Health
  • Disability status
  • Ethnic origin
  • Religious beliefs
  • Trade union membership
  • Criminal record information (where legally permitted)

We only collect and process Special Category Data where necessary and where an appropriate lawful basis applies.

How We Collect Information

We collect personal information:

  • Directly from you
  • Through job applications
  • Through CV submissions
  • Through interviews and conversations
  • Through referrals
  • From professional networking platforms such as LinkedIn
  • From job boards
  • From publicly available sources
  • From clients and referees
  • Through our website
  • Through cookies and analytics technologies

How We Use Your Information

We may use your personal information to:

Recruitment Services

  • Identify suitable opportunities
  • Assess suitability for roles
  • Present your profile to prospective employers
  • Arrange interviews
  • Conduct reference checks
  • Verify qualifications and employment history
  • Manage placements

Client Services

  • Deliver recruitment services
  • Manage assignments and searches
  • Maintain client relationships
  • Improve service quality

Business Operations

  • Administer contracts
  • Process payments and payroll
  • Maintain records
  • Respond to enquiries
  • Improve our services
  • Prevent fraud and misuse

Marketing

Where permitted by law, we may send:

  • Industry updates
  • Recruitment insights
  • Job opportunities
  • Company news
  • Service information

You may unsubscribe from marketing communications at any time.

Legal Basis for Processing

We process personal information under one or more of the following lawful bases:

Legitimate Interests

We process personal information where necessary for our legitimate interests, including:

  • Recruitment services
  • Candidate sourcing
  • Business development
  • Relationship management
  • Internal administration
  • Service improvement

We always balance our interests against your rights and freedoms.

Contract

We process information where necessary:

  • To fulfil contractual obligations
  • To take steps prior to entering into a contract
  • To administer employment and contractor arrangements

Legal Obligation

We may process information to comply with:

  • Employment law
  • Tax obligations
  • Immigration requirements
  • Regulatory requirements
  • Court orders and legal proceedings

Consent

Where required by law, we will obtain your consent before processing personal information.

You may withdraw consent at any time.

AI and Automated Technologies

Maxwell Stephens may use artificial intelligence, automation tools and recruitment technologies to support:

  • Candidate sourcing
  • CV analysis
  • Skills matching
  • Communication management
  • Recruitment administration
  • Data organisation and search

These tools assist our consultants but do not make final recruitment decisions independently.

All significant recruitment decisions involve human review and oversight.

Sharing Your Information

We may share personal information with:

  • Prospective employers and clients
  • Technology and software providers
  • Payroll providers
  • Professional advisers
  • Reference checking providers
  • Background screening providers
  • Government agencies
  • Regulators
  • Law enforcement authorities

We only share information where appropriate and lawful.

International Transfers

Some of our service providers may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we ensure appropriate safeguards are in place, including:

  • UK International Data Transfer Agreements (IDTAs)
  • Standard Contractual Clauses (SCCs)
  • Transfers to countries benefiting from UK adequacy regulations

Data Retention

We retain personal information only for as long as necessary.

Retention periods may vary depending on the nature of the relationship and legal obligations.

Examples include:

  • Candidate records: up to 7 years after last meaningful contact
  • Client records: up to 7 years
  • Financial and tax records: up to 7 years
  • Placement records: up to 7 years

Where retention is no longer necessary, information is securely deleted or anonymised.

Data Security

We take appropriate technical and organisational measures to protect personal information.

These measures include:

  • Access controls
  • Password protection
  • Encryption where appropriate
  • Secure cloud-based systems
  • Staff training
  • Supplier due diligence
  • Regular security reviews

While we take reasonable steps to safeguard information, no internet transmission can be guaranteed to be completely secure.

Your Rights

Under UK GDPR, you may have the right to:

  • Access your personal information
  • Correct inaccurate information
  • Request deletion of your information
  • Restrict processing
  • Object to processing
  • Request data portability
  • Withdraw consent
  • Challenge automated processing decisions

We will respond to valid requests within the timeframes required by law.

To exercise your rights, please contact:

info@maxwellstephens.com

Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

  • Operate essential website functions
  • Improve website performance
  • Analyse visitor behaviour
  • Measure marketing effectiveness
  • Enhance user experience

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

You may manage your cookie preferences through our cookie banner or browser settings.

Google Services and Analytics

We may use Google services including:

  • Google Analytics 4
  • Google Tag Manager
  • Google Ads
  • Google Forms
  • Google Maps

These services may collect information about how visitors use our website.

For further information regarding Google's privacy practices, please visit:

https://business.safety.google/privacy/

Third-Party Platforms

We may also use third-party platforms and technologies including:

  • LinkedIn
  • Microsoft
  • CRM platforms
  • Applicant Tracking Systems
  • Marketing automation tools
  • Cloud storage providers

Each provider processes data under its own privacy and security obligations.

Complaints

If you have concerns about how we process your personal information, please contact us first so we can try to resolve the matter.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Website: https://ico.org.uk

Telephone: 0303 123 1113

Contact Us

For any questions about this Privacy Policy or your personal information, please contact:

Maxwell Stephens Limited

Golden Cross House

8 Duncannon Street

London

WC2N 4JF

Email: info@maxwellstephens.com

Changes to This Policy

We may update this Privacy Policy from time to time.

Any changes will be published on this page and, where appropriate, notified to you by email or through our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Anti-Slavery and Human Trafficking Policy

1. Introduction

Maxwell Stephens Limited is committed to conducting its business ethically, responsibly and with integrity.

This policy sets out the steps we take to identify, assess and address the risk of modern slavery and human trafficking within our own operations and throughout our supply chains. We recognise our responsibility to maintain a robust and proportionate approach to preventing exploitation in every area of our business.

Maxwell Stephens has a zero-tolerance approach to modern slavery, forced labour, servitude, child labour and human trafficking. We are committed to ensuring that these practices have no place within our organisation or within the businesses and suppliers with which we work.

2. Purpose of This Policy

The purpose of this policy is to:

  • Communicate Maxwell Stephens’ commitment to preventing modern slavery and human trafficking.

  • Establish the standards expected from employees, workers, suppliers, contractors and business partners.

  • Support the identification, prevention and reporting of potential modern slavery risks.

  • Promote responsible and ethical practices across our operations and supply chains.

  • Provide a framework for responding appropriately where concerns or breaches are identified.

3. Scope

This policy applies to everyone working for Maxwell Stephens or acting on our behalf, including:

  • Directors and employees.

  • Temporary and agency workers.

  • Consultants and contractors.

  • Suppliers and subcontractors.

  • Business partners and other third parties providing goods or services to the company.

We expect all individuals and organisations within the scope of this policy to support and uphold its principles.

4. Our Commitments

Maxwell Stephens is committed to the following measures:

Zero Tolerance

We maintain a zero-tolerance approach to all forms of modern slavery and human trafficking within our organisation and supply chains.

Shared Responsibility

Preventing, identifying and reporting modern slavery is the responsibility of everyone working for us or on our behalf.

No employee, worker, supplier or business partner may engage in, facilitate, conceal or fail to report any activity that could result in, contribute to or suggest a breach of this policy.

Stakeholder and Supplier Engagement

We are committed to working constructively with suppliers, contractors and other stakeholders to identify and address modern slavery risks within our operations and supply chains.

Risk-Based Contracting

We take a proportionate, risk-based approach to our procurement and contracting arrangements and keep these processes under review.

Where appropriate, we may:

  • Include contractual provisions prohibiting modern slavery, forced labour and human trafficking.

  • Require suppliers and other third parties to comply with our standards or Code of Conduct.

  • Request information about the policies, procedures and controls used by suppliers to manage modern slavery risks.

  • Consider modern slavery compliance when selecting, reviewing or renewing supplier relationships.

Due Diligence and Monitoring

As part of our ongoing risk assessment and due diligence processes, we will consider whether additional checks or monitoring are appropriate.

Depending on the level of risk identified, this may include:

  • Requesting further information from suppliers.

  • Reviewing supplier policies and working practices.

  • Seeking evidence of compliance.

  • Requiring corrective action plans.

  • Conducting or commissioning audits where proportionate.

Appropriate Action

Where an individual or organisation working for us or on our behalf is found to have breached this policy, Maxwell Stephens will take appropriate action.

The action taken will depend on the nature and seriousness of the breach and may include:

  • Investigating the circumstances fully.

  • Requiring immediate corrective or remedial action.

  • Supporting remediation where this provides the best outcome for affected individuals.

  • Suspending or terminating a contract, appointment or business relationship.

  • Reporting the matter to the appropriate authorities where necessary.

Our response will prioritise the safety, welfare and rights of any individual affected by exploitation.

5. Reporting Concerns

Anyone who becomes aware of, or suspects, modern slavery or human trafficking within Maxwell Stephens’ operations or supply chains must report the concern promptly.

Concerns should be raised with an appropriate manager or senior representative of Maxwell Stephens. Reports will be treated seriously, sensitively and, wherever possible, confidentially.

No individual should suffer detrimental treatment for raising a genuine concern in good faith.

6. Training and Awareness

Maxwell Stephens will promote awareness of modern slavery risks and the responsibilities set out in this policy.

Where appropriate, employees and other relevant individuals may receive guidance or training to help them:

  • Recognise potential indicators of exploitation.

  • Understand how modern slavery risks may arise.

  • Know how and where to report concerns.

  • Apply appropriate due diligence when working with suppliers and third parties.

7. Governance and Review

Responsibility for overseeing this policy rests with the senior leadership of Maxwell Stephens Limited.

This policy will be reviewed periodically and updated where necessary to reflect changes in:

  • Legislation and regulatory guidance.

  • Business operations.

  • Supply-chain risks.

  • Industry standards and recognised best practice.

Maxwell Stephens remains committed to continually improving its approach to preventing modern slavery and human trafficking.