Privacy policy.

Last updated: 07 March 2026

GrowBright HR (“we”, “us”, “our”) is operated by Sofie Howard, sole trader. We are committed to protecting your personal data and being transparent about how we use it.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you interact with us — including as a client, website visitor, candidate, or supplier.

Data Controller:
Sofie Howard, trading as GrowBright HR
Email: hello@growbrighthr.co.uk
Business Location: Pontypridd, South Wales, UK
ICO Registration:

UK‑only business — no EU representative required.

1) What data we collect

We may collect and process:

Identity & Contact Data

Name, email address, phone number, job title, employer, postal address.

HR & Professional Data

CVs, job applications, work history, qualifications, interview notes, employee relations information (where working with clients), HR documentation.

Special Category Data

Only where strictly necessary and lawful (e.g., health data for reasonable adjustments).

Financial & Transaction Data

Invoices, payments, receipts, bank details (for suppliers/contractors).

Website & Technical Data

IP address, browser type, device information, and analytics cookies. UK guidance states websites using cookies must inform users and obtain consent where cookies are not strictly necessary.

Marketing Preferences

Email preferences and opt-ins.

2) How we collect your data

  • Directly from you via email, forms, or consultation

  • From clients (as part of HR services)

  • From candidates applying for roles

  • From public sources (e.g., LinkedIn)

  • Automatically through website cookies and analytics

3) How we use your data (purposes & lawful bases)

We use your data to:

Deliver HR services (legitimate interests/contract)

Providing HR consultancy, employee relations support, document creation, and training.

Recruitment activities (contract/legitimate interests)

Handling job applications, shortlisting, screening, and sharing profiles with clients.

Communications (legitimate interests)

Responding to enquiries, providing updates about services.

Marketing (consent or legitimate interests)

Sending optional newsletters or insights.

Compliance (legal obligation)

Financial record keeping, ICO compliance, tax obligations.

Website operation (legitimate interests/consent)

Using cookies to operate and improve our website; consent required for non-essential cookies.

4) When we act as a processor

Where a client engages GrowBright HR to process employee/candidate data on their behalf, the client is the data controller and we act as their processor, following their instructions.

5) Sharing your data

We may share your data with:

  • Clients (where relevant to services/candidate submissions)

  • IT and cloud service providers

  • Email/CRM systems

  • Accountants, legal advisers

  • Regulators where required

  • Website hosting and analytics tools (as applicable)

All providers are required to meet appropriate security standards.

6) International transfers

If any provider stores data outside the UK, we ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs).

7) Data retention

  • Client records: 6–7 years (legal requirement for HMRC purposes)

  • Candidate data: 12 months unless consented to remain on file longer

  • Financial records: 6 years

  • Marketing data: until you unsubscribe

  • Cookie data: per cookie expiry (see Cookie Policy)

8) Your rights

You can request to:

  • Access your data

  • Correct inaccurate data

  • Request erasure (where applicable)

  • Restrict processing

  • Object to processing

  • Withdraw consent

  • Make a complaint to the ICO

You can contact the ICO at www.ico.org.uk. A privacy notice is legally required when processing personal data.

9) Security

We apply reasonable technical and organisational measures, including:

  • Password protections

  • Secure cloud storage

  • Limited access controls

  • Multi-factor authentication

10) Changes to this policy

We may update this Privacy Policy occasionally. The latest version will always be available on our website.

11) Contact

If you have any questions:

Email: hello@growbrighthr.co.uk