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Privacy Policy
Last updated: 11 September 2026
The Lucent Group Ltd, trading as Lucent Search, is committed to protecting your personal information and respecting your privacy.
This Privacy Policy explains what personal information we collect, where we obtain it, how and why we use it, who we may share it with, how long we keep it, and the rights you have under UK data protection law.
For information about cookies and similar technologies used on our website, please see our separate Cookie Policy.
1. Who we are
The Lucent Group Ltd is the data controller responsible for the personal information described in this Privacy Policy where we determine how and why that information is processed.
Trading name: Lucent Search
Company: The Lucent Group Ltd
Company number: SC586559
Registered office: 2 Veere Park, Culross, KY12 8NE
Email: Rebecca@TheLucentGroup.co.uk
Telephone: +44 (0)131 381 8180
If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details above.
2. Who this Privacy Policy applies to
This Privacy Policy applies to personal information we process about candidates and potential candidates, clients and prospective clients, employees and representatives of organisations we work with or may wish to work with, referees, professional contacts, suppliers, advisers, people who contact or engage with us, and visitors to our website.
Our services are primarily directed towards organisations and business professionals.
3. Personal information we collect
The personal information we collect depends on our relationship with you and the reason we are processing your information.
For candidates and potential candidates, this may include your name, contact details, location, current and previous employers, job titles, professional experience, education, qualifications, curriculum vitae, LinkedIn or other professional profiles, career interests, remuneration and benefits information, notice period, eligibility to work, information provided during discussions with us, interview and assessment notes, references and other information relevant to an executive appointment.
For clients and prospective clients, this may include your name, employer, job title, professional contact details, areas of responsibility, correspondence, meeting notes, information about your organisation, leadership requirements, contracts, commercial information and records of our relationship with you.
We may also process information about communications with us, meetings, professional preferences, marketing preferences, website enquiries and other information reasonably required to operate our business and provide our services.
We aim to collect only information that is relevant and reasonably necessary for the purpose for which it is being used.
4. Where we obtain personal information
We may receive personal information directly from you when you contact us, send us your CV, participate in an executive search process, arrange or attend a meeting, provide information during an interview or discussion, subscribe to content, make an enquiry or otherwise communicate with us.
Executive search also involves identifying individuals who have not contacted us directly.
We may therefore obtain professional information about candidates, potential candidates, clients and prospective business contacts from sources including LinkedIn, LinkedIn Sales Navigator, company websites, Companies House, professional directories, industry publications, professional networks, conferences and events, recommendations, referrals, news and media sources, publicly available information and legitimate business-intelligence sources.
We may also receive information from clients, candidates, referees, former employers, colleagues, professional contacts and service providers.
Where data protection law requires us to provide privacy information because we obtained your information from another source, we will do so within the applicable legal timeframe.
5. Why we use personal information
We use personal information only where we have a lawful basis for doing so.
Our main processing activities and lawful bases are:
PurposeUsual lawful basis
Identifying and researching potential candidatesLegitimate interests
Contacting candidates about potentially relevant appointmentsLegitimate interests
Assessing and managing candidates during executive searchLegitimate interests and, where relevant, steps connected with a potential contract
Providing retained executive search and leadership advisory servicesContract and legitimate interests
Maintaining professional relationships with candidates and executivesLegitimate interests
Managing client relationshipsContract and legitimate interests
Responding to enquiriesLegitimate interests and, where relevant, steps before entering into a contract
Business administration, invoicing and record keepingContract, legitimate interests and legal obligations
Market mapping, leadership research and market intelligenceLegitimate interests
Business development and professional outreachLegitimate interests and, where required by law, consent
Sending research, content, invitations or other marketingLegitimate interests or consent, depending on the circumstances
Maintaining records of meetings and communicationsLegitimate interests
Protecting our systems, information and businessLegitimate interests and legal obligations
Establishing, exercising or defending legal claimsLegitimate interests
Compliance with regulatory, legal, tax or accounting obligationsLegal obligation
Where we rely on legitimate interests, we consider whether the processing is necessary for a legitimate purpose and whether your interests, rights or freedoms outweigh our interests.
6. Executive search and potential candidates
Lucent Search provides retained executive search and leadership advisory services.
As part of this work, we identify and research senior executives who may be relevant to current or future leadership appointments.
This may include individuals who have not applied for a role or previously contacted Lucent Search.
We may use professional information to understand executive talent markets, identify potential candidates, evaluate possible relevance to a particular search, maintain professional relationships and contact individuals about opportunities we reasonably believe could be relevant.
We may also undertake leadership market mapping, succession research, compensation research and analysis of executive talent markets.
Being included in our research or systems does not mean that we have made a decision about your suitability for a particular appointment.
We will not normally identify or present you to a client as a candidate for a specific appointment without first discussing the opportunity with you and obtaining your agreement to being presented.
7. Candidate assessment, references and due diligence
During an executive search, we may process information obtained through interviews, professional discussions, assessment, publicly available information and other people familiar with your professional experience.
Where appropriate, we may obtain references or use specialist providers for assessment, psychometric testing, background verification or other due diligence relevant to an appointment.
Any checks will be proportionate to the role and undertaken only where permitted by law.
8. Clients and prospective clients
We process information about current and prospective clients to provide our services, understand organisations and their leadership requirements, maintain professional relationships and develop Lucent Search's business.
This may include information about chief executives, board members, investors, technology, data and AI leaders, people leaders, talent professionals and other executives or senior decision-makers.
We may identify relevant organisations and individuals through our professional networks, LinkedIn, LinkedIn Sales Navigator, public information, referrals, research and business-intelligence activities.
9. Business development and direct marketing
We may contact individuals in their professional capacity where we reasonably believe Lucent Search's services, research, events or other professional information may be relevant to their responsibilities or organisation.
Our business development activities may include individual contact through email, telephone and LinkedIn. We may use professional business-development tools, including LinkedIn Sales Navigator and Dripify, to support this activity.
Where appropriate, we rely on our legitimate interests in developing professional relationships and promoting relevant services.
We also comply with the Privacy and Electronic Communications Regulations and other applicable direct-marketing requirements. Where the law requires consent for a particular communication, we will obtain it.
Different rules may apply to sole traders and certain partnerships compared with employees or representatives of limited companies and other corporate organisations.
You have the right to object at any time to the use of your personal information for direct marketing.
Where you opt out, we may retain limited information on a suppression list so that we can respect your preference and avoid contacting you again for marketing purposes.
We do not sell personal information to third parties for their own marketing purposes.
10. Meetings, calls and AI transcription
Some telephone, video or in-person meetings may be recorded, transcribed or summarised using technology such as Fireflies.ai.
We may use these tools to maintain accurate records of discussions, capture agreed actions, prepare meeting summaries, support executive search or advisory work and reduce reliance on handwritten notes.
Where a meeting is going to be recorded or transcribed, we will normally inform participants before or when recording begins.
If you would prefer not to be recorded or have a meeting transcribed, please tell us. Where reasonably practicable, we will use an alternative method of taking notes.
Recordings, transcripts and summaries may contain personal information and are treated as business records subject to appropriate security and retention controls.
A recording may be deleted once it is no longer required while relevant notes, summaries or parts of a transcript may be retained as part of the underlying client, candidate or business record.
11. Use of artificial intelligence
Lucent Search uses artificial intelligence tools, including ChatGPT and Claude, to support aspects of our work.
These tools may assist with activities including research, analysis, organising information, summarisation, drafting, preparation of interview or research materials and administrative work.
We seek to minimise the amount of personal information provided to AI services and do not intentionally provide sensitive personal information where it is unnecessary for the task.
Where provider controls allow us to do so, our accounts are configured so that information submitted through them is not used to train general-purpose AI models.
We use professional and business AI services according to the nature and sensitivity of the information being processed.
AI may assist our research or analysis, but Lucent Search does not use AI to make solely automated decisions about whether someone is suitable for an executive appointment, whether a candidate should be presented to a client, or other decisions producing legal or similarly significant effects.
Final executive-search decisions remain subject to human judgement.
12. Automated decision-making
We do not currently use solely automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.
If this changes, we will update this Privacy Policy and provide the additional information required by law.
13. Special-category personal information
Some types of personal information receive additional protection under data protection law.
These include information concerning health, race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic information, biometric identification, sex life and sexual orientation.
We do not generally need this information to identify or assess executives and do not intentionally infer sensitive characteristics from professional information.
There may be circumstances where special-category information is voluntarily provided or genuinely relevant, for example in relation to reasonable adjustments, accessibility or diversity information.
Where we process special-category information, we will have an appropriate lawful basis and an additional condition permitted under UK data protection law.
Where required, we will also maintain an Appropriate Policy Document setting out the safeguards applying to that processing.
14. Criminal-offence information
We do not routinely collect information about criminal convictions or offences.
For certain appointments, appropriate background checks may be required by an employer, regulator or applicable law.
Where Lucent Search processes criminal-offence information, we will do so only where permitted under UK data protection law and where an appropriate lawful basis and processing condition apply.
Where required, we will maintain an Appropriate Policy Document covering the safeguards and retention arrangements for this information.
15. Technology and service providers
We use third-party technology and professional service providers to operate Lucent Search and provide our services.
Our current technology providers include Recruiterflow for candidate, client and executive-search records; Microsoft for email, documents, productivity and communications; Calendly for scheduling; OpenAI/ChatGPT and Anthropic/Claude for AI-assisted work; Fireflies.ai for recording, transcription and meeting summaries where used; Dripify for professional business development; LinkedIn and LinkedIn Sales Navigator for professional research and relationship development; and Wix for our website.
We may change or add providers as our business and technology requirements evolve.
Where another organisation processes personal information on our behalf, we require appropriate contractual, confidentiality and security protections where applicable.
16. Who we may share information with
Personal information may be shared where necessary with clients in connection with an executive search, referees, assessment or background-check providers, professional advisers, lawyers, accountants, insurers, consultants, IT and technology providers and other organisations that support our business.
We may also disclose information where required by law, court order, regulator or other lawful authority, or where necessary to establish, exercise or defend legal claims.
If our business or substantially all of its assets were sold, reorganised or transferred, personal information may also form part of that transaction subject to applicable legal safeguards.
We do not sell personal information.
17. International transfers
Some of the technology and service providers we use operate internationally.
Personal information may therefore be processed, stored or accessed outside the United Kingdom.
Where this constitutes a restricted transfer under UK data protection law, we use an appropriate legal transfer mechanism.
Depending on the provider and destination, this may include UK adequacy regulations, the UK Extension to the EU-US Data Privacy Framework where applicable, the UK International Data Transfer Agreement, the UK Addendum to approved European Commission Standard Contractual Clauses, or another mechanism permitted by UK law.
We take reasonable steps to ensure that appropriate safeguards apply to personal information transferred internationally.
18. How long we keep personal information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, taking into account legal obligations, the nature of our relationship with you and legitimate business requirements.
Candidate and executive-search information may be retained while it remains reasonably relevant to future executive search, leadership-market research, career opportunities or our professional relationship with you. We periodically review records and may update, anonymise or delete information that is no longer required.
Client, contractual, financial and related business records may normally be retained for up to seven years after the end of the relevant relationship or transaction where this is appropriate for accounting, tax, contractual or legal-claims purposes.
Professional business-development information may be retained while an individual remains a relevant business contact. Where an individual objects to direct marketing, limited information may be retained on a suppression list so that we can continue to respect that preference.
Recordings and AI-generated transcripts are retained only for as long as they continue to serve a relevant business purpose. Information forming part of an underlying candidate, client, contractual or legal record may be retained for the period applicable to that record.
We may retain information for longer where necessary to establish, exercise or defend legal claims or comply with legal or regulatory requirements.
We may also anonymise information so that it can no longer reasonably identify an individual. Anonymous information may be retained and used for research, analytical or statistical purposes.
19. Data security
We use appropriate organisational and technical measures designed to protect personal information from accidental or unlawful loss, destruction, alteration, disclosure or access.
Access to personal information is limited according to business need.
We consider relevant privacy and security factors when selecting service providers and use contractual protections where appropriate.
No internet-based or electronic storage system can be guaranteed to be completely secure.
Where we become aware of a personal-data breach, we will assess and respond to it in accordance with applicable law, including notifying affected individuals or the Information Commissioner's Office where legally required.
20. Your rights
Depending on the circumstances, UK data protection law may give you rights to be informed about how your information is used; request access to information we hold about you; ask us to correct inaccurate or incomplete information; request deletion in certain circumstances; request restriction of processing; object to processing based on legitimate interests; object at any time to direct marketing; request portability of certain information; withdraw consent where processing relies on consent; and receive safeguards in relation to qualifying automated decision-making.
These rights are not absolute and legal exemptions may apply.
Where you withdraw consent, this does not affect processing that took place lawfully before the withdrawal.
To exercise any of your rights, contact:
You will not normally be charged for exercising these rights.
We may ask for information necessary to confirm your identity before disclosing information or acting on a request.
We will normally respond within one month. Where data protection law permits an extension, we will tell you.
21. Data protection complaints
If you have concerns about how we have collected, used, retained, disclosed or otherwise processed your personal information, you can make a data protection complaint directly to us.
Please contact:
Rebecca Hastings
The Lucent Group Ltd trading as Lucent Search
Rebecca@TheLucentGroup.co.uk
Please provide enough information for us to understand and investigate your concern.
We will acknowledge a data protection complaint within 30 days, investigate it appropriately and communicate the outcome to you.
We may contact you for further information where this is necessary to understand or investigate your complaint.
22. Complaints to the Information Commissioner's Office
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.
You do not have to complain to Lucent Search before contacting the ICO, although we would welcome the opportunity to resolve your concern directly where possible.
Further information about your rights and how to make a complaint is available from the Information Commissioner's Office at ico.org.uk.
23. Our website
When you use our website, we may process technical and usage information necessary to provide, secure and administer the site.
Depending on your choices, analytics services may also process information about how you find and interact with the website.
Our use of cookies, Google Analytics, Wix Analytics and similar website technologies is explained separately in our Cookie Policy.
Information submitted through a website contact form is used to respond to your enquiry and for any other purpose clearly explained when you provide the information.
Our website may contain links to websites or services operated by third parties. We are not responsible for their privacy practices and recommend reviewing their privacy information separately.
24. Changes to this Privacy Policy
We may update this Privacy Policy where our services, technology, processing activities or legal obligations change.
The current version will always be published on our website and the date at the top of this page will be updated.
Where a change materially affects how we process existing personal information, we may also bring it to the attention of affected individuals where appropriate.