LEGAL / PRIVACY
Privacy Policy
LAST UPDATED · 21/08/2026
1. About this policy
This policy explains how MARK22 LTD (“MARK22”, “we”, “us”, “our”) collects and uses personal information, and what rights you have in relation to that information. This policy covers our clients, business contacts, website visitors, suppliers and anyone who contacts us. We are the data controller for the personal information described in this policy.
If you are a candidate or prospective candidate, please read our Candidate Privacy Notice, which explains in detail how we handle candidate information.
2. Who we are and how to contact us
Company
MARK22 LTD
Trading as
MARK22
Company number
17413098
Registered in
England and Wales
Registered office
4–6 Greatorex Street, London, England, E1 5NF
Website
ICO registration number
Not provided
MARK22 is registered with the Information Commissioner’s Office (ICO) as a data controller and pays the required data protection fee. Registration with the ICO is a legal requirement for most UK organisations that process personal data. It is not a certification, endorsement or approval of our practices. For any privacy question, request or complaint, contact us at general@mark22.co.uk.
3. Who this policy applies to
Client contacts — people at companies who use, or have used, our recruitment services
Prospective clients and business contacts — hiring managers, engineering leaders, founders, directors and other decision-makers at companies we may approach about recruitment services
Website visitors — anyone visiting mark22.co.uk
Enquirers — anyone who contacts us by form, email, phone or messaging
Suppliers and service providers — our own contacts at organisations we work with
4. Client contacts
What we process
Name, job title, employer, work email address, work telephone number, correspondence with us, records of vacancies discussed, interview arrangements, feedback on candidates, and contractual and billing information.
Where it comes from
Directly from you, from colleagues at your organisation, from your company’s website, or from professional sources such as LinkedIn.
Why we process it
To discuss and understand your recruitment requirements; to source and introduce candidates; to arrange interviews; to manage placements; to invoice and take payment; to keep records of our dealings; and to comply with our legal and tax obligations.
Lawful basis
Contract — where you are contracting with us personally, or where processing is necessary to take steps at your request before entering a contract
Legitimate interests — to operate and administer our recruitment business and maintain our client relationships. Where our client is a company rather than an individual, processing information about you as its representative is necessary for our legitimate interest in performing that contract and managing the relationship
Legal obligation — for tax, accounting and statutory record-keeping
5. Prospective clients and business development
We research and contact people who hold relevant hiring or decision-making roles at technology companies, to introduce our recruitment services and to discuss roles they may be hiring for.
What we process
Name, job title, employer, business contact details, publicly available professional profile information (for example a LinkedIn profile), and a record of our contact with you.
Where it comes from
Publicly available and professional sources, including company websites, LinkedIn and other professional platforms; job advertisements; referrals; and information you give us directly.
Why we process it
To identify organisations that may need specialist DevOps, Platform and Cloud Engineering recruitment support, and to make relevant, targeted contact with the right person at that organisation.
Lawful basis
Legitimate interests — our interest in promoting our recruitment services to organisations likely to need them, and in reaching the individual within that organisation who is responsible for hiring. We only use business contact details in a professional context, we keep the volume of contact proportionate, and we stop contacting you if you ask us to.
Electronic marketing
Where we send marketing emails, we do so in line with the Privacy and Electronic Communications Regulations 2003 (PECR):
We send marketing email to corporate subscribers (limited companies, LLPs and other corporate bodies) without prior consent, which PECR permits, but we always identify ourselves clearly and give you a simple way to opt out
We do not send unsolicited marketing email to sole traders or unincorporated partnerships without consent or an existing relationship, because PECR treats them as individual subscribers
Every marketing message includes an opt-out. You can also opt out at any time by emailing general@mark22.co.uk
Your right to object: because we rely on legitimate interests, you have the right to object to this processing at any time. If you object, we will stop and, unless we have a compelling reason not to, remove you from our prospecting records.
6. Website visitors and enquiries
Contact form: our website includes a contact form. When you use it we collect the information you enter (typically your name, email address, and the content of your message) together with the date and time of submission.
Why we process it: to read, assess and respond to your enquiry, and to keep a record of it.
Lawful basis: legitimate interests — responding to enquiries made to our business. Where your enquiry is about engaging our services, we may also process it to take steps at your request before entering a contract.
7. Suppliers and service providers
We process the names, job titles, business contact details and correspondence of our contacts at organisations that supply goods or services to us, in order to manage those relationships, place and receive orders, and handle payments. Lawful basis: contract, and legitimate interests in managing our supplier relationships.
8. Who we share information with
We do not sell personal information. We may share it with:
Service providers who process data on our behalf — including our email, document storage, CRM, website, communications, accounting and banking providers (see section 9)
Our professional advisers — accountants, lawyers and insurers, where relevant
HMRC, regulators and law enforcement — where we are legally required to disclose information
A buyer or successor — if we sell or restructure the business, subject to appropriate protections
Where a client’s personal information is relevant to a candidate introduction (for example the name of the hiring manager a candidate will meet), we share only what is necessary for the recruitment process.
9. Systems and providers we use
We currently use, or may use, the following categories of provider:
Business email and document storage
Microsoft 365 / Outlook
CRM and candidate/client database
Airtable
Website hosting
Framer
Professional networking, sourcing and business development
Business messaging
WhatsApp Business
Business banking
Starling Bank
Accounting and bookkeeping
Xero
We may also use other recruitment, communications or cloud providers where necessary. We put written terms in place with providers who process personal information on our behalf.
10. International transfers
Some of our providers are based outside the UK, or store or access data outside the UK — including in the United States and the European Economic Area.
Where personal information is transferred outside the UK, we rely on one or more of the following:
The country having UK adequacy status (this includes the EEA)
The UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses
The UK Extension to the EU–US Data Privacy Framework, where the receiving organisation is certified under it
11. How long we keep information
Client and business contact records
6 years from the end of our relationship
Prospective client / business development records
24 months from last meaningful contact, then reviewed
Website enquiries that do not progress
12 months
Contracts and correspondence relating to placements
6 years from the end of the relevant engagement
Accounting and tax records
6 years, in line with HMRC requirements
We review the information we hold periodically and delete or anonymise what we no longer need. Where you object to marketing or prospecting, we keep a minimal suppression record so that we do not contact you again.
12. Security
We take reasonable technical and organisational measures to protect personal information, including access controls on our systems, multi-factor authentication where available, use of reputable providers, and limiting access to information to what is needed.
No system can be guaranteed completely secure, and we cannot guarantee the security of information sent to us over the internet. If a personal data breach occurs that is likely to result in a risk to individuals, we will notify the ICO and, where required, affected individuals.
13. Your rights
Under UK data protection law you have the right to:
Be informed about how we use your information
Access a copy of the personal information we hold about you
Rectification of inaccurate or incomplete information
Erasure of your information in certain circumstances
Restrict processing in certain circumstances
Data portability in certain circumstances
Object to processing based on legitimate interests — including profiling
Object to direct marketing at any time; this is an absolute right and we will always comply
Withdraw consent at any time, where we rely on consent
You also have the right not to be subject to decisions producing legal or similarly significant effects that are based solely on automated processing. We do not make such decisions.
To exercise any right, email general@mark22.co.uk. We will respond within one month. There is normally no charge. We may ask you to confirm your identity before we act on a request.
14. Complaints
If you are unhappy with how we have handled your personal information, please contact us first at general@mark22.co.uk so we can try to resolve it.
You also have the right to complain to the Information Commissioner’s Office at any time:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
15. Changes to this policy
We may update this policy from time to time. The current version is always available at mark22.co.uk, and the “last updated” date at the top shows when it was last revised. Where changes are significant, we will take reasonable steps to bring them to your attention.