Last updated: 4 May 2026

1. About this privacy notice

Shrewd HR Ltd respects your privacy and is committed to protecting your personal information.

This privacy notice explains how we collect, use, store and share personal information when you:

It also explains your rights and how to contact us if you have a question or concern about how we use your information.

2. Who we are

Shrewd HR Ltd is a private limited company registered in England and Wales.

Company name: Shrewd HR Ltd
Company number: 12761498
Registered office: Durham Cricket, Banks Homes Riverside, Chester-le-Street, County Durham, DH3 3QR
Telephone: 0191 375 5770
Email: [email protected]
Website: shrewd-hr.co.uk

For most of the personal information covered by this notice, Shrewd HR Ltd is the data controller. This means we decide why and how that information is used.

We have not appointed a formal Data Protection Officer. Questions about privacy and data protection should be sent to the contact details above.

3. When we act on behalf of our clients

As an HR consultancy, we may handle personal information about a client’s employees, workers, contractors, job applicants and former employees.

In many of these circumstances, the client organisation is the data controller and Shrewd HR acts as its data processor. We only use the information in accordance with the client’s documented instructions and our agreement with them.

This may include information relating to:

Where your information has been provided to us by your employer or another organisation, you should usually direct a data protection request to that organisation first. We will assist our client in responding where required.

There may be limited circumstances where Shrewd HR acts as an independent controller, including where we must keep information to meet our own legal obligations, protect our legal rights, manage conflicts or respond to a complaint or legal claim.

4. The personal information we collect

The information we collect depends on your relationship with us.

Identity and contact information

This may include your:

Enquiry and communication information

This may include:

Please avoid sending sensitive personal or employee information through a general website enquiry form unless it is necessary.

Client and business information

This may include:

Financial and transaction information

This may include:

We do not normally collect complete payment card details directly through the website.

Training and event information

This may include:

Marketing information

This may include:

Recruitment information

Where you apply for a role with Shrewd HR, this may include:

Website and technical information

When you use our website, we may collect:

Further information is provided in our Cookie Policy.

5. Special category and criminal offence information

Some personal information receives additional protection under data protection law. This includes information about health, disability, racial or ethnic origin, religious beliefs, trade union membership, sexual orientation and certain other sensitive matters.

Because we provide HR and employment support, we may need to process this type of information when dealing with sickness absence, reasonable adjustments, workplace concerns, equal opportunities, employee relations or legal claims.

We will only use special category information where:

We only process criminal offence information where we have a lawful basis and the processing is authorised by law.

6. How we collect your information

We may collect information:

7. How and why we use personal information

We must have a lawful basis for each way in which we use personal information.

PurposeLawful basis
Responding to enquiries and discussing possible servicesSteps requested before entering into a contract and our legitimate interest in responding to business enquiries
Preparing proposals and setting up a client relationshipContract or steps before a contract, and legitimate interests where the contract is with an organisation
Delivering HR consultancy, employment law support, training and related servicesContract, legitimate interests and legal obligations
Handling information on a client’s instructionsWe normally act as a processor under our contract with the client
Managing client accounts and communicationsContract and our legitimate interest in providing an effective service
Issuing invoices, taking payment and maintaining financial recordsContract and legal obligation
Administering training courses and eventsContract, steps before a contract and legitimate interests
Sending newsletters, event invitations and promotional emailsConsent where required, or legitimate interests where business-to-business marketing is permitted
Recording marketing preferences and opt-outsLegal obligation and legitimate interests
Understanding website use through non-essential analyticsConsent
Maintaining website security and preventing misuseLegitimate interests and legal obligation
Managing complaints, disputes and legal claimsLegitimate interests, legal obligation and the establishment, exercise or defence of legal claims
Recruiting employees and contractorsSteps before a contract, legitimate interests and legal obligations
Managing suppliers and professional advisersContract and legitimate interests
Publishing agreed testimonials, case studies, photographs or videoConsent or legitimate interests, depending on the circumstances
Improving our services, processes and client experienceLegitimate interests

Where we rely on legitimate interests, these may include operating and improving our business, responding to enquiries, maintaining professional relationships, protecting our systems, keeping appropriate records and communicating with relevant business contacts.

We consider the effect of the processing on the people involved and do not rely on legitimate interests where their rights and interests outweigh ours.

8. Marketing communications

We may send you newsletters, employment law updates, event information and details of our services where:

You can unsubscribe at any time by:

Withdrawing consent does not affect the lawfulness of anything we did before consent was withdrawn.

You have an absolute right to object to the use of your personal information for direct marketing. When you object, we will stop using it for that purpose.

We may keep a minimal suppression record containing your email address or other contact details so that we can respect your request and avoid contacting you again.

We do not sell personal information to advertisers or mailing list providers.

9. Cookies and website analytics

Our website uses cookies and similar technologies.

Some cookies are necessary for the website to function properly. Other cookies, including analytics cookies, should only be used where you have given the appropriate consent.

Where enabled with your consent, Google Analytics may collect information about how visitors find and use the website. This helps us understand which pages are useful and identify areas that could be improved.

You can accept, reject or change your choices through the website’s cookie consent controls. You can also manage cookies through your browser settings.

More information about the cookies in use, their purpose and how long they remain on your device should be provided in our separate Cookie Policy.

10. WhatsApp, social media and external platforms

Our website includes links to WhatsApp, LinkedIn, Instagram and other external websites or platforms.

When you select one of these links, the relevant provider may collect information about you in accordance with its own privacy notice. Shrewd HR does not control how an external platform uses information collected through its service.

Where you contact us through WhatsApp or social media, we may retain relevant messages in our own business records where this is necessary to respond to you or manage our relationship.

Our website may also use third-party review or content widgets. These services may receive technical information when they are loaded, subject to your cookie choices and the provider’s own privacy practices.

11. Who we share personal information with

We only share personal information where there is a proper reason to do so.

Recipients may include:

Where another organisation processes personal information on our behalf, we require it to protect the information and only use it for the agreed purpose.

Where we introduce you to an independent partner, that partner may become a separate data controller. It should provide its own privacy information explaining how it will use your details.

12. International transfers

Some technology, email, analytics, communication or cloud service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we take appropriate steps to protect it. Depending on the destination and provider, these may include:

Further information about the safeguards used for a particular provider can be requested using the contact details in this notice.

13. How long we keep personal information

We keep information only for as long as it is reasonably needed for the purpose for which it was collected, including legal, accounting and reporting requirements.

Our usual retention periods are:

InformationUsual retention period
General enquiries that do not become clientsUp to 24 months after the last meaningful contact
Client contracts, advice and relationship recordsNormally up to seven years after the relationship ends
Financial and accounting recordsNormally six years after the relevant financial year
Newsletter and marketing recordsUntil you unsubscribe or object
Marketing suppression recordsFor as long as needed to ensure your opt-out is respected
Training and event administration recordsNormally up to two years after the event
Unsuccessful recruitment applicationsNormally six months after the recruitment process ends
Recruitment talent pool informationUp to two years where separate consent has been obtained
Website analyticsFor the period stated in the Cookie Policy or analytics settings
Complaints and related correspondenceNormally up to six years after the complaint is closed
Information processed for a clientIn accordance with the client’s instructions and our agreement with them

We may retain information for longer where this is necessary because of an ongoing complaint, investigation, legal claim, regulatory requirement or safeguarding concern.

Information that is no longer required will be securely deleted, destroyed or anonymised.

14. How we protect personal information

We use appropriate organisational and technical measures to protect personal information from accidental loss, misuse, unauthorised access, alteration or disclosure.

These measures may include:

No online system can be guaranteed to be completely secure. Where we become aware of a personal data breach, we will investigate it and notify affected individuals and the Information Commissioner’s Office where required by law.

15. Your data protection rights

Depending on the circumstances and the lawful basis being used, you may have the right to:

Some rights are subject to legal conditions and exemptions. For example, we may need to retain information where there is a legal requirement or an ongoing legal claim.

To exercise a right, email [email protected] with the subject line Data protection request.

We may need to ask for information to confirm your identity. We will respond within the applicable legal timescale and will not normally charge a fee.

16. Automated decision-making

We do not use information collected through the website to make decisions about you solely by automated means where those decisions would have legal or similarly significant effects.

Where automated tools are used as part of a client service, their use and the applicable safeguards will be considered separately. Any significant decision should include appropriate human involvement and oversight.

17. Children’s information

Our website and services are intended for businesses and working professionals. They are not directed at children, and we do not knowingly collect personal information directly from children through the website.

We may process limited information about children where this is necessary when providing HR support to a client, for example in relation to family leave or employee benefits. In these circumstances, we process the information on the client’s instructions and apply appropriate safeguards.

18. Making a data protection complaint

You can raise a concern or complaint by emailing [email protected] and using the subject line Data protection complaint.

Please include:

We will acknowledge a data protection complaint within 30 days, investigate it without undue delay, keep you appropriately informed and explain the outcome.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection. You do not need to complete our internal complaints process before contacting the ICO, although we would appreciate the opportunity to address your concern directly.

19. External links

Our website may contain links to websites operated by other organisations.

We are not responsible for the privacy, security or content of external websites. You should read the privacy notice of any external service before providing personal information to it.

20. Changes to this notice

We may update this privacy notice when our services, systems or legal obligations change.

The date at the top of the notice shows when it was last reviewed. Significant changes may also be highlighted on the website or communicated directly where appropriate.

21. Contact us

Questions, requests and complaints about this privacy notice or our use of personal information should be sent to:

Shrewd HR Ltd
Durham Cricket
Banks Homes Riverside
Chester-le-Street
County Durham
DH3 3QR

Email: [email protected]
Telephone: 0191 375 5770