Vulnerability Management Recruitment
Baxter Wells Ltd

Privacy Policy

1. Who we are

Baxter Wells Ltd ("Baxter Wells", "we", "us") is a specialist Vulnerability Management recruitment business. We help US companies hire senior Vulnerability Management professionals. We are the data controller for the personal information described in this policy, which means we decide how and why it is used.

We are registered with the UK Information Commissioner's Office (ICO), registration number ZC265347. We are a small business and do not need a Data Protection Officer. Charlotte is responsible for data protection and will deal with any privacy questions personally.

2. Who this policy covers and what we collect

This policy covers four groups of people. We only collect what we need to recruit well.

WhoWhat we collect
Candidates (people we contact about roles, or who contact us)Name, job title, employer, work history, skills, certifications, education, location, professional profile links, contact details (email, phone), CV, salary and package details, notice period, job preferences, right-to-work status where a client needs it, interview notes and feedback, and our messages with you
Client contacts (hiring managers and others at companies we work with or approach)Name, job title, company, business contact details, notes of our conversations, and details of roles you are hiring for
RefereesName, job title, contact details and the reference you give
Website visitorsBasic technical data such as IP address, browser type and pages visited, and anything you send us through the site

We do not ask for special category data (such as health, ethnicity, religion or sexual orientation). If you choose to tell us something like this, for example to request adjustments for an interview, we will only use it for that purpose and with your agreement.

3. Where we get your information

Most of what we hold comes from you or from professional information you have made public.

If we collect your details from a source other than you, we will point you to this policy when we first contact you, and within one month at the latest.

4. How and why we use your information

We use your information to match the right people with the right roles. UK data protection law requires a lawful basis for each use, set out below.

What we doLawful basis
Find and contact professionals who may be interested in Vulnerability Management rolesLegitimate interests: running a specialist recruitment business
Assess your suitability for roles and keep notes of our conversationsLegitimate interests; and steps you ask us to take before entering a contract
Introduce you to a client and send them your CV or profileLegitimate interests, and we always tell you and get your agreement before sharing your details with a client for a specific role
Arrange interviews, collect feedback and support offersLegitimate interests; steps towards a contract
Contact client businesses about hiring needs and our servicesLegitimate interests
Deliver our services to clients, invoice and keep business recordsContract; legal obligation (tax and accounting)
Check right to work or references when a client asks us toLegal obligation or legitimate interests, with your knowledge
Keep our website working and secureLegitimate interests

When we rely on legitimate interests, we have weighed our interests against yours. We only approach people about roles relevant to their professional experience, we use business contact details, and you can ask us to stop at any time.

We do not make decisions about you by automated means alone. We may use software, including AI tools, to help us search, organise notes and draft messages, but a person always makes the decisions.

5. Who we share your information with

We never sell your information. We share it only where needed to recruit or run the business.

ServiceWhat it does for us
SpottRecruitment database (candidates, clients, notes)
Google WorkspaceEmail, calendar and document storage
Apollo.io, FullEnrichBusiness contact data
ExaSearching public professional information
LinkedInProfessional networking and messaging
RingoverBusiness calls and text messages
Anthropic (Claude)AI assistant used for research, notes and drafting
NetlifyWebsite hosting
WiseBusiness banking and payments
Our accountantBookkeeping and tax

6. Sending information outside the UK

Our clients and several of our service providers are in the United States, so your information will be transferred there. When we transfer personal data out of the UK, we make sure it is protected by one of the following:

You can ask us for details of the safeguard that applies.

7. How long we keep it and how we protect it

We keep information only as long as it is useful for recruitment or required by law.

InformationHow long
Candidate records2 years from our last meaningful contact with you, then deleted or anonymised unless you ask us to keep you on file
Candidates we have placed6 years after the placement, for contract and tax records
Client contact records2 years from our last contact, or 6 years after our last invoice to that client
Financial and invoicing records6 years, as required by UK tax law
Anyone who asks us not to contact themA minimal record (name and contact detail) kept only so we do not contact you again

We protect your information with access-controlled accounts, two-factor authentication, encrypted devices and reputable service providers. Only Baxter Wells staff who need your information can see it. If a data breach is likely to put you at risk, we will tell you and the ICO as the law requires.

8. Your rights

You have rights over your information, and exercising them is free. To use any of them, email charlotte@baxterwells.com. We will reply within one month.

If you live in a US state with its own privacy law, such as California, you may have similar rights. Contact us in the same way and we will help.

9. How we contact you: email, phone and text messages

We contact professionals individually about relevant roles. We do not send bulk marketing.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent are excluded from all of the sharing described in section 5 and will not be shared with any third parties.

If you tell us to stop contacting you by any channel, we will record it and stop.

10. Cookies, changes and complaints

Cookies: our website does not use advertising or tracking cookies. Our hosting provider may keep basic technical logs to keep the site secure. If we add analytics or other cookies, we will update this policy and ask for your consent where required.

Changes: we may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.

Questions and complaints: please contact Charlotte Barber at charlotte@baxterwells.com first, and we will do our best to put things right. You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113.

Last updated: 3 October 2026