Policies
Modern Slavery and Human Trafficking Policy
Last reviewed: June 2026
1. Our Position
Glass Harbour Group (trading as Glass Harbour Consulting) has a zero-tolerance approach to modern slavery and human trafficking in all its forms. We are committed to acting ethically and with integrity in all our business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chain.
2. Our Business
Glass Harbour Consulting is a boutique recruitment consultancy placing insurance professionals and superyacht crew. We operate on a contingency basis, introducing candidates to client businesses for permanent employment. We do not employ temporary workers, operate a payroll, or manage supply chains involving labour intermediaries.
In accordance with the Maritime Labour Convention (MLC) 2006, we do not charge seafarers any recruitment or placement fees. Candidates are never charged for our services.
3. Our Commitment to Candidates
We are committed to ensuring that every candidate we work with engages with us freely and without coercion. Specifically:
We do not charge candidates fees for finding them work
We do not withhold identity documents or personal information
We do not use or facilitate deceptive recruitment practices
We respect every individual’s right to end their engagement with us at any time
We verify the right to work of candidates we place in the UK in accordance with legal requirements
4. Due Diligence
Where we introduce candidates to clients, we take reasonable steps to satisfy ourselves that the hiring organisation operates lawfully and treats workers fairly. We will not knowingly work with any business that we have reason to believe engages in practices inconsistent with this policy.
5. Reporting
Any person with concerns about modern slavery or human trafficking in connection with Glass Harbour Group is encouraged to raise them promptly. Concerns can be reported to us directly at enquiries@glassharbour.com. Individuals also have the right to report concerns to the relevant authorities, including the National Crime Agency or the Modern Slavery Helpline (0800 0121 700).
6. Review
This policy will be reviewed annually and updated as necessary to reflect changes in our business or relevant legislation.
Anti-Bribery and Anti-Corruption Policy
Last reviewed: June 2026
1. Our Position
Glass Harbour Group (trading as Glass Harbour Consulting) has a zero-tolerance approach to bribery and corruption. We are committed to conducting all business honestly, transparently and with integrity, and to complying fully with the Bribery Act 2010.
2. What This Policy Covers
This policy applies to all activities carried out by or on behalf of Glass Harbour Group. It covers:
Offering, promising or giving a bribe
Requesting, agreeing to receive or accepting a bribe
Bribing a foreign public official
Failing to prevent bribery by an associated person
A bribe is any financial or other advantage offered, given or received to induce a person to act improperly, or as a reward for doing so.
3. Gifts and Hospitality
We recognise that reasonable and proportionate gifts and hospitality are a normal part of professional relationship-building. However, gifts or hospitality must never be offered or accepted where they could be perceived as an attempt to influence a business decision or create an obligation.
We do not offer or accept gifts of significant monetary value, cash, or anything that could reasonably be construed as an inducement. Any gifts or hospitality of note will be recorded.
4. Fees and Commissions
All fees charged by Glass Harbour Consulting are disclosed transparently in our written terms of business. We do not pay referral fees, undisclosed commissions or any other payments designed to influence the award of business.
5. Reporting
Any person with concerns about potential bribery or corruption in connection with Glass Harbour Group is encouraged to raise them promptly at enquiries@glassharbour.com. Concerns can also be reported to Action Fraud (actionfraud.police.uk) or the Serious Fraud Office (sfo.gov.uk).
6. Review
This policy will be reviewed annually and updated as necessary to reflect changes in our business or relevant legislation.
Candidate Privacy Policy
Last reviewed: June 2026
1. Who We Are
Glass Harbour Group (trading as Glass Harbour Consulting) is a boutique recruitment consultancy specialising in the placement of yacht crew and insurance professionals. We act as a data controller in respect of the personal information we collect and process about candidates.
If you have any questions about this notice or how we handle your data, please contact us at:
Email: kp@glassharbour.com
Address: 54 Bridge Street, Christchurch, BH23 1EB
2. What Personal Data We Collect
In the course of our recruitment activities, we may collect and process the following categories of personal data:
Contact details (name, address, email address, telephone number)
Identity and right to work documents (passport, visa, nationality)
Professional information (CV, work history, qualifications, certifications such as STCW and ACCA)
References and employment history
Salary expectations and availability
Any additional information you choose to provide to us
Where relevant to the roles we are recruiting for, we may also collect information that is considered sensitive personal data, such as health information required for medical fitness certificates. We will only collect this where strictly necessary and with your explicit consent.
3. How We Collect Your Data
We collect personal data directly from you when you register with us, submit a CV, or engage with us by email, telephone, or through our website. We may also receive your details from third parties such as referees or professional networks, where you have consented to your information being shared.
4. Our Legal Basis for Processing
We rely on the following lawful bases to process your personal data:
Legitimate interests: to provide recruitment services, match candidates to suitable roles, and manage our business operations.
Contract: where processing is necessary to take steps at your request prior to entering a contract, or to perform a contract with you.
Legal obligation: where we are required to process data to comply with our legal obligations, such as right to work verification.
Consent: where we ask for your explicit consent, for example when processing sensitive personal data or when contacting you about roles after an initial engagement has concluded. You may withdraw consent at any time.
5. How We Use Your Data
We use your personal data to:
Match you to suitable vacancies and present your profile to prospective employers or clients
Communicate with you about relevant opportunities
Carry out reference checks and verify your right to work
Maintain our candidate database for future opportunities (with your consent)
Comply with our legal and regulatory obligations
We will not submit your details to any client without first discussing the role with you and obtaining your agreement.
6. Who We Share Your Data With
We may share your personal data with:
Prospective employers and clients, where you have agreed to be put forward for a specific role
Referees, where you have provided their details and consented to reference checks being carried out
Third-party service providers who support our business operations (such as our CRM provider), where they are bound by appropriate data processing agreements
We do not sell your personal data to any third party.
7. International Transfers
Given the international nature of the yacht and insurance industry, your personal data may on occasion be shared with clients or employers based outside the UK or European Economic Area. Where this occurs, we will ensure that appropriate safeguards are in place in accordance with UK GDPR requirements.
8. How Long We Keep Your Data
We will retain your personal data for as long as is necessary to provide our recruitment services to you and to comply with our legal obligations. If you are placed into a role, we will retain relevant records for a minimum of six years in accordance with standard legal requirements.
If you register with us but are not placed, we will generally retain your data for up to 24 months from your last contact with us, after which it will be securely deleted unless you consent to us retaining it for longer.
9. Your Rights
Under UK data protection law, you have the following rights in respect of your personal data:
The right to access the personal data we hold about you
The right to rectification if any data we hold is inaccurate or incomplete
The right to erasure ('right to be forgotten') in certain circumstances
The right to restrict processing of your data
The right to data portability
The right to object to processing based on legitimate interests
The right to withdraw consent at any time, where processing is based on consent
To exercise any of these rights, please contact us using the details in Section 1. We will respond within one calendar month.
10. Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection supervisory authority, at www.ico.org.uk or by calling 0303 123 1113.
11. Changes to This Notice
We may update this privacy notice from time to time. The most current version will always be available on request.