Privacy policy

01Who we are

Imperium Commodity Search is a specialist brand of MET Recruitment (London) Ltd, company number 08793838. In this notice, “Imperium”, “we”, “us” and “our” mean that company. We are the controller of the personal information we use for the purposes described here.

Our address is Staple House, 5 Eleanor’s Cross, Dunstable, Bedfordshire, LU6 1SU, United Kingdom.

We provide retained recruitment search, executive search, headhunting, market mapping and related advisory services across commodities, shipping and financial markets. This notice covers candidates and prospective candidates, client and supplier contacts, referees and visitors to our website.

We handle personal information under applicable data protection law, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003, as amended, including by the Data (Use and Access) Act 2025. Where other data protection laws apply to our activities, we also comply with those requirements.

02Your privacy contact

Use these details to ask how we handle your information, exercise your rights or raise a complaint. You do not need to use a particular form or legal wording.

03The information we collect

We collect information relevant to our relationship with you. Depending on the circumstances, this may include:

• Contact and professional details: your name, contact details, employer, job title, business location and professional profile.
• Career information: your CV, employment history, qualifications, skills, sector experience, career interests, location preferences, availability and remuneration expectations or information you choose to provide.
• Search and relationship records: correspondence, meeting notes, interview feedback, assessments, references, proposed introductions and placement information.
• Client and supplier information: business contact details, hiring requirements, instructions, contracts, invoices and records of our dealings.
• Verification information: identity, qualifications, references and right-to-work information where relevant and necessary for a particular assignment or legal requirement.
• Website information: information submitted through our forms, IP addresses, browser and device information, security logs, website usage and cookie preferences.
• Privacy preferences: consent records, communication preferences, objections and requests concerning your information.

Please avoid including unnecessary sensitive information in a CV or enquiry. We do not need bank details, National Insurance numbers or next-of-kin details for an initial search discussion.

04Where information comes from

We receive information directly from you through applications, conversations, meetings, email and website forms. We may also obtain relevant professional information from LinkedIn and other publicly accessible professional profiles, company websites, industry publications, job boards and professional information services, as well as referrals, clients, referees and other professional contacts.

Direct research is part of our search work, so we may identify and approach you even if you have not registered with us. Public availability does not remove your data protection rights.

If we obtain your information from another source, we explain the source and provide this privacy information within the applicable legal timeframe: normally no later than one month, or at our first communication with you or first disclosure of your information, if earlier, unless a lawful exception applies.

05How and why we use information

We identify a lawful basis for each purpose. The principal purposes and bases are set out below.

When relying on legitimate interests, we consider whether the processing is necessary and balance those interests against your rights and reasonable expectations. You can ask us about that assessment.

Where we rely on consent, you can withdraw it at any time. Withdrawal does not affect earlier lawful processing. We will stop the activity covered by that consent; we may retain limited information for a separate, lawful purpose, such as meeting a legal duty or recording your objection.

You do not have to provide every detail we request. If particular information is required by law, by a contract with you or to progress a search, we will explain why and what may happen if you do not provide it.

06Sensitive information and checks

Special category information includes health, racial or ethnic origin, religious beliefs and other information given additional protection by law. We only process it where necessary for a specific purpose and where both a lawful basis and an additional legal condition apply. For example, relevant health information may be needed to arrange an interview adjustment.

Depending on the circumstances, the additional condition may be your explicit consent, a requirement connected with employment rights or obligations, or the establishment, exercise or defence of legal claims. We meet any additional safeguards required by the Data Protection Act 2018.

Criminal offence information is subject to separate restrictions. Any such check must be relevant, proportionate and authorised by law. Where a check is needed, we explain its purpose and how the information will be handled before obtaining it.

07Who we share information with

We share relevant information only where there is a lawful basis and a need connected with the purposes in this notice. Recipients may include:

• Hiring organisations: relevant decision-makers involved in a proposed appointment, including associated businesses involved in that appointment. We discuss proposed introductions with candidates before sending an identifiable CV or candidate presentation.
• Candidates and professional contacts: relevant client contact information, role requirements and information needed to progress a search.
• Referees and verification providers: where references or checks are relevant and have been discussed with the candidate.
• Service providers: providers of recruitment and contact-management software, email, hosting, document management, research support, communications, analytics and IT security, where used to support our services.
• Professional advisers and authorities: accountants, lawyers, insurers, regulators, courts and other authorities where necessary or legally required.

Providers acting as our processors must handle information under appropriate contractual instructions and protections. Hiring organisations and some advisers or providers act as independent controllers and are responsible for their own processing and privacy information.

If our business is sold, merged or reorganised, relevant information may be disclosed to advisers and prospective or new owners where necessary, with confidentiality and data protection safeguards.

08International transfers

Our work is international. Information may be shared with hiring organisations, candidates or service providers outside the United Kingdom, or accessed from another country when providing support. The destination depends on the assignment and the services involved.

Where a transfer is restricted under UK data protection law, we use an applicable lawful transfer mechanism. This may be UK adequacy regulations or appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses, with the required assessment of the protection provided. A specific statutory exception is used only where its conditions are satisfied.

Where EU GDPR transfer rules also apply, we meet those requirements. Contact Zuzana for information about the destinations relevant to your information and a copy or explanation of the safeguards, with confidential information redacted where necessary.

09How long we keep information

We keep personal information only for as long as it is needed for the relevant purpose. We consider the nature of the information, our relationship with you, your preferences, legal duties and any reasonable need to deal with a dispute.

• Candidate and professional relationship records: normally up to six years after our last meaningful contact or the last service we provided, subject to earlier deletion where information is no longer needed. We review continuing relevance; a publicly available profile alone does not justify keeping a record indefinitely.
• Contracts, placements and financial records: for the applicable statutory retention period and any justified period needed to establish, exercise or defend legal claims.
• Sensitive information, checks and identity documents: only for the specific purpose and any applicable legal retention requirement, with a shorter period where these details are no longer necessary.
• Website logs and cookies: for periods appropriate to their security or technical purpose. Cookie durations are shown in the website’s Cookie Preferences information.
• Objection and suppression records: limited information for as long as necessary to respect your request not to be contacted and demonstrate that we have acted on it.

Where a legal requirement or an active dispute justifies longer retention, we retain only the information needed for that purpose. When information is no longer required, we delete it securely or anonymise it. You can ask us about the retention period applicable to your record.

10Technology and human judgement

We use technology to support research, organise information and assist our work. Search and filtering tools may help us identify relevant professional experience. Our consultants remain responsible for assessing candidates and making recommendations.

We do not make decisions about you that have legal or similarly significant effects solely by automated means. If that changes, we will explain the processing and the safeguards and rights that apply before using it.

If a call or meeting is to be recorded or transcribed, we will tell you before it starts and explain the purpose, the lawful basis and your available choices.

11Website cookies and communications

Our website uses cookies and similar technologies for essential operation and security, to remember choices and, where enabled, to understand how the website is used. The website’s Cookie Preferences panel lists the technologies, providers, purposes and durations currently declared for the site.

Where consent is legally required, your agreement is needed before optional technologies are used. You can accept, reject or change optional choices through the site’s cookie controls. An exemption from consent applies only where all its legal conditions are met. Necessary technologies support functions such as security and remembering your privacy choices.

You can also control cookies in your browser, although disabling necessary cookies may affect website functions. External websites and platforms linked from this site have their own privacy information.

You can stop direct marketing at any time by using the unsubscribe option provided or contacting us. We will stop using your information for that purpose. This does not prevent necessary communications about an active instruction, application, privacy request or legal matter.

12Keeping information secure

We use technical and organisational measures appropriate to the information and the risks, including restricting access to people who need it for their work and requiring appropriate protection from our service providers. We review these arrangements as our systems and services change.

No system is entirely risk-free. If a personal data breach occurs, we assess it and notify the relevant regulator and affected individuals where the law requires.

13Your rights

Depending on the circumstances, you may have the right to:

• Access your personal information and receive a copy.
• Have inaccurate or incomplete information corrected.
• Ask for information to be erased or its use restricted.
• Object to processing based on legitimate interests, on grounds relating to your situation.
• Object to direct marketing at any time, including related profiling.
• Receive information you provided in a portable format, where the processing is automated and based on consent or a contract with you.
• Withdraw consent where we rely on it.
• Receive applicable safeguards for significant automated decisions, including human intervention and the opportunity to express your views and challenge a decision.
• Complain to a supervisory authority.

These rights are subject to the conditions and exemptions in data protection law. Contact Zuzana to make a request. We may ask for information reasonably needed to verify your identity or clarify your request.

We normally respond to rights requests within one calendar month and without a fee. Where the law permits an extension or a pause to obtain necessary information, we will explain this. If an extension is needed because a request is complex or there are several requests, we will explain the reason within the initial response period; the extension may be up to two further months.

14Questions and complaints

If you are concerned about how we handle your information, contact Zuzana using the details above. You can complain by email, telephone or post.

We will acknowledge your data protection complaint within 30 days of receiving it. We will investigate, keep you informed and explain the outcome without undue delay. A complaint that also includes a rights request will be handled under the applicable rules and timescales for each.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). See ico.org.uk/make-a-complaint/. Where another country’s data protection law applies, you may also have the right to contact the relevant supervisory authority.

15Changes to this notice

We review this notice when our services, practices or legal obligations change. The date at the top identifies the latest version. Where required, we will bring a material change to your attention before using your information for a new purpose.