WCS Project Phoenix Ltd | Last updated: 5 June 2026
1. Who We Are
WCS Project Phoenix Ltd (“WCS”, “we”, “us”, “our”) is a UK-based recruitment and workforce consultancy. We operate at wcsprojectphoenix.uk.
Data Controller: WCS Project Phoenix Ltd
Contact: shawn@wcsprojectphoenix.uk
ICO Registration: Pending (applied under Tier 1, £40/year)
2. What Personal Data We Collect
| Category | Examples | Source |
|---|---|---|
| Identity | Name, job title | You, LinkedIn, public sources |
| Contact | Email address, phone number | You, NHS Jobs, LinkedIn |
| Professional | Employer, role, skills, work history | You, CV, LinkedIn, job boards |
| Usage | Website visits, email opens | Automatically via cookies |
| Communications | Emails, messages sent to us | You |
3. How We Use Your Data
- Recruitment services – matching candidates to roles and pitching to employers
- Business development – contacting potential clients and partners
- Compliance – meeting legal and regulatory obligations
- Communications – responding to enquiries and sending relevant updates
4. Our Legal Basis (UK GDPR)
| Purpose | Legal Basis |
|---|---|
| Recruitment matching | Legitimate interests (Art. 6(1)(f)) |
| Client outreach | Legitimate interests (Art. 6(1)(f)) |
| Contractual obligations | Contract (Art. 6(1)(b)) |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
| Marketing (opt-in) | Consent (Art. 6(1)(a)) |
5. Who We Share Your Data With
We do not sell your personal data. We may share it with:
- Client employers (only for the purpose of recruitment, with your knowledge)
- IT and software service providers (Google Workspace, CRM tools)
- Regulatory bodies (HMRC, ICO) where legally required
6. International Transfers
Some of our tools (e.g. Google) may process data outside the UK. Where this occurs, we ensure adequate safeguards are in place under UK GDPR transfer mechanisms.
7. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Candidate data (active) | Duration of engagement + 2 years |
| Candidate data (inactive) | 3 years from last contact |
| Client/prospect data | 5 years from last business interaction |
| Financial records | 7 years (legal requirement) |
8. Your Rights
Under UK GDPR you have the right to:
- Access – request a copy of your personal data
- Rectification – correct inaccurate data
- Erasure – request deletion (“right to be forgotten”)
- Restriction – limit how we process your data
- Portability – receive your data in a machine-readable format
- Object – object to processing based on legitimate interests
- Withdraw consent – at any time where processing is consent-based
To exercise any right, email shawn@wcsprojectphoenix.uk. We will respond within 30 days.
9. Cookies
Our website uses essential cookies only. No tracking or advertising cookies are set without your explicit consent.
10. Security
We use industry-standard security measures including encrypted connections (HTTPS), access controls, and regular security reviews to protect your personal data.
11. Complaints
If you are unhappy with how we handle your data, you have the right to complain to the Information Commissioner’s Office (ICO):
ico.org.uk/make-a-complaint | 0303 123 1113
12. Changes to This Policy
We may update this policy from time to time. The “Last updated” date at the top of this page will reflect any changes. Continued use of our services after changes constitutes acceptance.
WCS Project Phoenix Ltd | shawn@wcsprojectphoenix.uk | wcsprojectphoenix.uk