Privacy Notice

Privacy Notice
Version: 1.1
Policy Issued: 22 July 2025

Head Immigration is a migration business which provides immigration and visa application services to its clients. We must process personal data (including special category personal data) in order to provide these services. In providing these services, personal data is processed under the control of Head Resourcing Limited, which is the data controller for the purposes of UK data protection law.

You may provide your personal details to us directly, for example by completing an application or registration form, through our website, by email, by telephone, or through our online portal. We may also collect information from other sources with your permission, such as government agencies, partner referrals, family members or friends.

We must have a lawful basis for processing your personal data. For the purposes of providing immigration services and information relating to immigration matters relevant to you, we will only use your personal data in accordance with this Privacy Notice. We will comply with applicable data protection legislation at all times.

Contents

1. Collection and use of personal data 
   1. Purpose of processing and legal basis 
   2. Legitimate interest
   3. Statutory/contractual requirement
   4. Recipients of data
   5. Categories of data
   6. Sources of data
2. Overseas transfers
3. . Data retention
4. Your rights
5. Cookies
6. Login files
7. Links to external sites
8. Sale of the business
9. . Data security
10. Changes to this privacy statement
11. Complaints or queries

1. Collection and use of personal data

a. Purpose of Processing and Legal Basis

The Company will collect your personal data (which may include special category personal data) and process it for the purpose of providing immigration services.

This includes, for example:

• Assessing your suitability for different immigration and visa routes;
• Providing immigration advice and support;
• Preparing, managing and submitting visa applications on your behalf;
• Communicating with you regarding your immigration matter;
• Maintaining accurate records;
• Developing and improving our services;
• Managing our relationship with you and other relevant stakeholders;
• Creating and administering secure online client accounts and portals; and
• Allowing clients to access, review, update and upload information and documents in connection with immigration services.

If you have opted in to receive marketing communications, we may also send you information about our services via email or text message. You can opt out at any time by selecting the unsubscribe option included in our communications or by contacting us.

On certain occasions, we may be required to use your personal data for the purpose of investigating, reporting or detecting crime, complying with legal obligations, or undertaking internal and external audits to demonstrate compliance with applicable laws, professional standards and industry requirements.

We must have a lawful basis for processing your personal data. The lawful bases we rely upon for providing immigration services are:

• Performance of a contract; and
• Legitimate interests.

We process special category personal data under the condition of Explicit Consent under Article 9 UK GDPR and criminal offence data under the relevant provisions of the Data Protection Act 2018.

We will seek your consent to this processing through our written service agreement before providing services. Where special category information is required to prepare or submit an immigration application, withdrawing consent may mean we are unable to continue providing some or all of our services.

b. Legitimate interest

We may process your personal data where doing so is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests include:

• Responding to enquiries made through our website, email or telephone;
• Managing our records and keeping them accurate and up to date;
• Providing immigration services to you, including visa-related services;
• Contacting you to obtain consent where required;
• Informing you about similar services that may be relevant to you;
• Ensuring compliance with legal and regulatory obligations;
• Demonstrating compliance with professional standards and industry requirements;
• Meeting the audit and compliance requirements of professional licensing bodies with which our immigration advisers are registered; and
• Maintaining the security and integrity of our systems and services.

When we assist you with obtaining a visa, our collection and use of personal information may also be influenced by the requirements of the country issuing the visa.

c. Statutory/contractual requirement

We process your personal data where it is necessary to perform our contract with you, or to take steps at your request before entering into a contract.

This includes:

• Assessing your immigration requirements and advising on available immigration routes;
• Preparing, managing and submitting immigration and visa applications on your behalf;
• Communicating with you regarding your matter;
• Obtaining and reviewing supporting documentation;
• Creating and administering your online client account and portal;
• Collecting payment for services provided; and
• Maintaining records relating to the services we provide to you.

 Where we are unable to process the personal data necessary for these purposes, we may be unable to enter into, or fulfil, our contractual obligations to you.

d. Statutory/ Contractual Requirement

The Company has certain legal and contractual requirements to collect personal data, including obligations relating to immigration law, taxation, anti-money laundering requirements, and safeguarding responsibilities where applicable. 

We may require certain personal information in order to enter into and perform a contract with you. If you do not provide the information that we require to satisfy these obligations, we may not be able to provide immigration services to you.

e. Recipients of data: The Company will collect the following personal data on you:

The Company may share your personal data and, where relevant, special category personal data with the following recipients: 

• Head Immigration uses a client relationship management and database platform operated by Head Medical, a trading division of Head Resourcing Limited, to record correspondence and documents relating to immigration services. Although the platform is primarily designed for recruitment activities, immigration client data is only accessed and processed by authorised Head Immigration personnel for the purposes of delivering immigration services, maintaining records, managing client communications and securely storing documentation.
• Government agencies responsible for administering immigration and visa processes.
• Partner organisations that provide services relevant to your immigration matter where an introduction has been requested or authorised.
• Former employers where references are required.
• Head Medical recruitment services where you have requested or consented to an introduction for recruitment opportunities. Head Immigration and Head Medical operate as separate business functions and do not routinely share client information. Any sharing of information for recruitment purposes will only occur where you have requested this service or authorised the disclosure.
• Auditors and regulatory bodies undertaking compliance reviews, professional licensing audits, or assessments of our business processes.
• Third-party suppliers who support the delivery of our services, including software providers, secure document storage providers, finance systems, website hosting providers, analytics providers and email service providers.

f. Categories of data: The Company may collect the following categories of personal data:

Personal Data 

• Name
• Address
• Telephone number
• Email address
• Nationality
• Marital status
• Family information
• Date and place of birth
• Country of intended migration
• Government identification documents and reference numbers, including passport details, birth certificates and National Insurance numbers
• Employment history
• Professional qualifications and job title
• Educational background
• Military history (where applicable)
• Travel history
• Payment and transaction information

 Where required for the provision of services, we may also collect supporting documentation such as passports, CVs, educational certificates, visa documentation, birth certificates and other evidence relevant to your immigration matter.

 Special Category Data

Depending upon your circumstances and the requirements of the immigration authorities involved, we may collect: 

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Genetic data
• Biometric data
• Health information, including disability information
• Information relating to criminal convictions or offences
• Information concerning sex or sexual orientation

g. Sources of Data: We may obtain data from 

• You directly;
• Family members;
• Friends;
• Government agencies;
• Former employers;
• Referees whose details you have provided;
• Software providers supporting our services;
• Cookies and similar technologies;
• Publicly available sources such as LinkedIn and professional directories.

2. Overseas Transfers

We may transfer your personal information to government authorities, immigration and visa processing bodies, professional or skills assessment bodies, employers, educational institutions and other organisations located outside the United Kingdom where this is necessary to provide the immigration services you have requested. This may include organisations located in Australia, New Zealand and other countries relevant to your immigration matter.

Where your personal information is transferred outside the United Kingdom, we will ensure that the transfer is made in accordance with applicable UK data protection legislation and that an appropriate lawful international transfer mechanism applies. Depending on the circumstances, this may include UK adequacy regulations, appropriate safeguards, or an applicable exception under UK data protection legislation.

3. Data retention

The Company will retain your personal data only for as long as necessary for the purposes for which it was collected.

 Where immigration records are subject to professional licensing requirements, client files will normally be retained for a minimum period of seven years following closure of the matter.

 After this period, records will be securely deleted unless we are required to retain them for longer to comply with legal, regulatory, insurance or legitimate business requirements.

 Where we rely on consent for the processing of personal data or special category personal data, we will process such information in accordance with our retention policies and applicable legal requirements.

4. Your rights

You have the following rights under data protection legislation:

• The right to be informed about how your personal data are processed;
• The right of access to your personal data;
• The right to rectification of inaccurate or incomplete personal data;
• The right to erasure in certain circumstances;
• The right to restrict processing in certain circumstances;
• The right to data portability in certain circumstances;
• The right to object to processing based on legitimate interests;
• The right not to be subject to automated decision-making; and
• The right to withdraw consent at any time where processing is based on consent. 

Where you have provided consent, you may withdraw it at any time by contacting:

dataprivacy@headimmigration.com

Withdrawal of consent will not affect any processing carried out before consent was withdrawn or any processing based on another lawful basis.

If you believe that any information we hold about you is inaccurate or incomplete, please contact us and we will take reasonable steps to investigate and, where appropriate, rectify the information.

5. Cookies

We may obtain information about you through cookies and similar technologies. Cookies are small text files placed on your device by websites you visit. 

We use cookies to:

• Enable website functionality;
• Improve website performance;
• Understand user behaviour;
• Remember preferences; and
• Support website analytics and marketing activities. 

In most cases, the information collected through cookies does not directly identify you. 

Most web browsers allow you to manage cookie preferences through browser settings. Please note that disabling cookies may affect the functionality of certain parts of our website.

6. Login Files

We use IP addresses to analyse trends, administer our website, monitor user activity and collect demographic information for aggregate reporting purposes.

IP addresses are not ordinarily linked to personally identifiable information.

7. Links to external websites

Our website may contain links to other websites.

Please note that we are not responsible for the privacy practices or content of external websites. We encourage you to review the privacy notices of any third-party websites you visit.

This Privacy Notice applies only to information collected by Head Immigration.

8. Sale of business

If the business is sold, merged or otherwise integrated with another organisation, your personal information may be disclosed to our professional advisers and prospective purchasers and their advisers.

 Where this results in a change of data controller, we will notify you accordingly.

9. Data Security

The Company takes appropriate technical and organisational measures to protect personal information from loss, misuse, unauthorised access, disclosure, alteration or destruction.

Security measures include: 

• Password protection;
• Role-based access controls;
• Firewall and network security protections;
• Encryption where appropriate; and
• Secure storage and backup processes. 

Access to personal information is restricted to employees who require the information in order to perform their duties. 

Although we take reasonable steps to protect your information, no method of internet transmission or electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted via email or the internet. 

Where available, we encourage clients to submit passports, identity documents, visa documentation and other supporting evidence through our secure online portal rather than by email. Documents uploaded through the portal are stored within our secure client management system and may be accessed only by authorised personnel involved in providing services to you. 

If you share a device with others, we recommend that you do not select any “remember my details” functionality where offered.

10. Changes to this privacy statement

We may update this Privacy Notice from time to time. 

Any updates will be published on our website together with the revised version number and effective date. Where changes are significant, we will take reasonable steps to notify affected individuals.

11. Complaints or queries

If you have any questions regarding this Privacy Notice or our handling of your personal data, please contact:

dataprivacy@headimmigration.com 

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your personal information has been processed unlawfully. 

Information Commissioner’s Office

Telephone: 0303 123 1113

Website: https://ico.org.uk/make-a-complaint/ 

If your personal data is processed outside the UK, you may also have the right to raise concerns with the relevant supervisory authority in the country concerned.