How we use your data

At this stage, our only interest is to fully address and progress your enquiry in line with your wishes. In practice, this means that:

  • When we receive your enquiry, we will set up an account for you in our CRM system to help us manage your enquiry as efficiently as possible. We’ll use this account to record your details and our interactions with you.
  • We will check our CRM system to see if you’re already registered with us or have been in the past. When combined with the details that you or your recruiter have given as part of your enquiry, this allows us to personalise our communications with you and to make our messages as relevant as possible to your circumstances.
  • We’ll use your contact details to communicate with you regarding your query. This could include email, phone calls or SMS to your mobile. Please see the interaction methods section of our privacy policy for more information about the data processing that happens around each of these activities.

Our lawful basis for collecting, storing and using your data in this way is legitimate interests, because we believe it’s in both your interests and ours to respond to your enquiry and tell you about how Key Portfolio can support you. This data processing allows us to give it our best effort.

If you change your mind at any point and decide you’re no longer interested in joining, please let us know and we won’t contact you anymore.


We may update your recruitment consultant to let them know whether or not you’ve joined and why. Keeping your agency updated means they know how to get your payments to you and helps prevent delays. Therefore, our lawful basis for doing so is legitimate interests.

If you are registered with a recruitment agency that we don’t currently have a relationship with, we will contact that agency and ask if we can work together to support you. Having this conversation with your agency is the only way we can determine whether or not you’d be able to use our services and without doing so, we’d be unable to respond to your query accurately or fully. Therefore, our lawful basis for doing this is legitimate interests.

We may share your data with our carefully chosen data processors. These are trusted businesses who help us communicate with you, work more productively and keep your data secure. Our lawful basis for this processing is legitimate interests.

It happens infrequently, but we would share information if requested to do so by a law enforcement agency or in response to a court order. Similarly, we have a duty to disclose information about possible criminal acts (e.g. money laundering) or security threats to the relevant bodies. Our lawful basis for this processing is legal obligation.

Should you raise or require support with a legal case, we may choose to share your personal data with a lawyer. In the event that it included ‘special category’ data, for example details relating to your health, trade union membership or religion, then we would be doing so on the basis that it is necessary for the establishment, exercise or defence of a legal claim. Our lawful basis for this processing is legitimate interests.

In certain circumstances, we may ask the Home Office to confirm your immigration status. For example, we would do this if you were in the process of applying for or renewing your work visa and didn’t yet have the necessary documentation to show us. We would ask for your permission to submit your details to the Employer Checking Service provided by the Home Office, so that we could confirm you had the right to work in the UK while your application was ongoing. In this scenario, our lawful basis for collecting this data is legal obligation.

What we don’t do with your data
  • We will not pass your details to any third party not mentioned in this policy, unless we have your consent to do so. Should we need to introduce a new third party, for example because the law changes, we would update this privacy policy.
  • If we’re making a decision that could have a significant effect on you, we would not base it solely on automated processing. To clarify, decisions related to your employment status would always involve a human.
  • We will not transfer your personal data outside the European Union, except to countries that have been recognised by the European Commission as providing adequate protection for your data. Learn more: when would you transfer my data outside the EU?

You have the right to object to any processing that is based on legitimate interests. To let us know that you object, please email

Go to section 4 – storing your data >>