Privacy Notice
Last updated: 01 July 2026
Version: PN V26.08
1. Introduction
LIFEGUARD respects the privacy and confidentiality of individuals whose personal data it receives, handles or otherwise processes.
This Privacy Notice explains how The LIFEGUARD Organisation, trading publicly as LIFEGUARD and, where applicable, as LIFEGUARD Ltd. (“LIFEGUARD”, “we”, “us” or “our”), processes personal data in connection with:
- access to and use of the website at lifeguard.org and related LIFEGUARD web pages;
- communications with the Private Office, Personnel Office or other published LIFEGUARD contact channels;
- preliminary enquiries concerning potential advisory, intelligence, security, investigative, recruitment or other professional engagements;
- applications for positions advertised through the Careers section; and
- associated website-security, administrative, legal and compliance activities.
This Notice does not replace any engagement-specific privacy notice, data-processing schedule, recruitment notice, employment notice, contractual provision or other information provided in connection with a particular mandate, client relationship, investigation, recruitment process or professional service.
Certain LIFEGUARD assignments may involve heightened confidentiality, legal privilege, professional secrecy, security-sensitive information or other specialised information-governance requirements. In such circumstances, the relevant engagement documentation and applicable law may provide additional or more specific protections.
2. Who Is Responsible for Your Personal Data
The controller responsible for personal data processed under this Privacy Notice is:
LIFEGUARD Ltd.
Trading as: LIFEGUARD
Registered office: Gußhausstraße 6, 1040 Vienna
Company or registration number: FN599594g
Jurisdiction of incorporation: Austria | HG Wien
For privacy-related enquiries, please contact:
Privacy Office
Email: privacy@lifeguard.org
Where LIFEGUARD appoints a Data Protection Officer, EU representative, UK representative or Swiss representative, the relevant contact details will be stated here:
Data Protection Officer
Charles S. Davis, LLM
Email: dpo@lifeguard.org
LIFEGUARD operates through, and may work with, appropriately selected entities, advisers and specialist providers in a number of jurisdictions. The identity of the controller for a particular professional mandate, employment relationship or recruitment process may differ from the website controller. Where this is relevant, LIFEGUARD will provide additional information at the appropriate time.
3. Applicable Privacy Framework
LIFEGUARD seeks to process personal data in accordance with applicable privacy, data-protection, electronic-communications, employment and confidentiality laws.
Depending on the circumstances, this may include:
- the European Union General Data Protection Regulation, or GDPR;
- applicable Austrian data-protection and electronic-communications laws;
- applicable Maltese data-protection laws;
- the Swiss Federal Act on Data Protection, or FADP;
- the United Kingdom General Data Protection Regulation, or UK GDPR;
- the United Kingdom Data Protection Act 2018;
- applicable electronic-communications and cookie requirements; and
- other mandatory laws applicable to the relevant processing activity, individual, controller, service provider or jurisdiction.
This Notice is intended to provide a clear and transparent overview of LIFEGUARD’s website-related processing activities. It does not limit any mandatory rights available to individuals under applicable law.
4. Personal Data We May Collect
The personal data LIFEGUARD processes will depend on the nature of your interaction with us.
4.1 Website and Technical Information
When you access the website, we or our hosting and security providers may process limited technical information, such as:
- Internet Protocol, or IP, address;
- browser type and version;
- operating system and device information;
- referring website or source;
- pages visited, date and time of access, and general interaction data;
- technical logs, error reports and security-event information;
- cookie or similar-technology preferences;
- information required to protect the website against misuse, unauthorised access or malicious activity.
This information is primarily used to operate, protect, maintain and improve the website.
4.2 Private Office and General Correspondence
Where you contact LIFEGUARD by email, telephone or other approved communication channel, we may process:
- your name;
- organisation, position or professional role;
- business or personal contact details;
- country or jurisdiction;
- the subject matter of your enquiry;
- information contained in your correspondence or attachments;
- communication preferences;
- records of communications, follow-up actions and conflict-review steps.
You should not send classified, legally privileged, highly sensitive personal, operationally restricted or commercially confidential material through ordinary email before an appropriate secure communication channel has been agreed.
4.3 Potential Client, Adviser and Professional Contact Information
Where you approach LIFEGUARD regarding a potential engagement, we may process information reasonably necessary to:
- understand the nature of the proposed matter;
- evaluate whether we have the capacity and appropriate expertise to assist;
- conduct conflict, integrity, client-acceptance and suitability review;
- identify relevant legal, regulatory, sanctions, jurisdictional or professional considerations;
- establish appropriate communication and engagement arrangements.
Depending on the circumstances, this may include professional background information, organisation details, beneficial ownership or authority information, relevant counterparties, jurisdictions, business context and other information reasonably necessary for preliminary assessment.
4.4 Recruitment and Careers Information
If you apply for a role advertised by LIFEGUARD, we may process information contained in your application or otherwise provided during the recruitment process, including:
- name and contact details;
- curriculum vitae and covering note;
- professional and employment history;
- qualifications, licences, certifications and language capability;
- driving-licence status or other role-relevant eligibility information;
- references and referee contact details;
- interview notes and assessment results;
- right-to-work, immigration or employment-eligibility information;
- relevant background, integrity, security, fitness, licensing or vetting information, where lawful, necessary and appropriate to the role;
- correspondence and administrative records relating to the application.
For security-sensitive roles, additional information may be required at a later stage. LIFEGUARD will seek to collect such information only where there is a clear legal basis, a genuine operational requirement and an appropriate secure process.
Applicants should not provide passports, identity cards, service records, weapons documentation, security-clearance documentation, medical information, criminal-record documentation or other sensitive material at the initial application stage unless specifically requested through an appropriate channel.
4.5 Information Received from Other Sources
LIFEGUARD may receive personal data from sources other than the individual concerned, where this is lawful and appropriate. Such sources may include:
- authorised representatives;
- clients or prospective clients
- professional advisers;
- recruitment agencies or referees;
- publicly available professional sources;
- corporate registries and official records;
- regulatory or governmental sources;
- third-party service providers;
- specialist due-diligence, screening or verification providers;
- other sources reasonably relevant to a lawful and defined purpose.
Where required by applicable law, LIFEGUARD will provide relevant information about such indirect processing within the applicable timeframe, subject to lawful exemptions, confidentiality obligations, legal privilege, security considerations and restrictions.
5. Purposes and Legal Bases for Processing
LIFEGUARD processes personal data only where there is a lawful basis and a defined purpose.
Depending on the jurisdiction and the circumstances, our principal legal bases may include:
- the performance of a contract or steps taken at your request before entering into a contract;
- compliance with a legal obligation;
- LIFEGUARD’s legitimate interests or those of a client, adviser or relevant third party, provided that these interests are not overridden by your rights and interests;
- consent, where consent is required or appropriate;
- the establishment, exercise or defence of legal claims;
- other lawful grounds permitted under applicable privacy law.
| Processing activity | Purpose | Principal legal basis or basis |
|---|---|---|
| Operating and securing the website | To provide, maintain, secure and troubleshoot the website, prevent misuse and preserve system integrity | Legitimate interests; legal obligations where applicable |
| Responding to correspondence | To respond to enquiries, manage communications and assess requests for information or support | Steps taken at your request; legitimate interests |
| Private Office assessment | To assess prospective mandates, conduct preliminary conflict and suitability review, and establish secure contact arrangements | Steps taken at your request; legitimate interests; legal obligations where applicable |
| Client acceptance and compliance | To undertake lawful due diligence, conflict review, sanctions screening, fraud-prevention measures, professional-risk assessment and recordkeeping | Legal obligations; legitimate interests; establishment, exercise or defence of legal claims |
| Careers and recruitment | To assess applications, verify eligibility, conduct interviews and assessments, manage recruitment, and communicate with applicants | Steps taken at your request; legitimate interests; legal obligations where applicable |
| Recruitment for security-sensitive roles | To assess suitability, integrity, licensing, security, legal eligibility and operational requirements, where permitted by law | Legitimate interests; employment-law obligations; legal obligations; other applicable lawful grounds |
| Management of legal and professional risk | To protect LIFEGUARD, its clients, personnel, systems, advisers and professional relationships | Legitimate interests; legal obligations; establishment, exercise or defence of legal claims |
| Cookies and similar technologies | To enable necessary website functionality and, where used, manage optional technologies | Necessary processing; consent for non-essential technologies where required |
Where LIFEGUARD relies on legitimate interests, those interests may include maintaining a secure and professional website, responding appropriately to genuine enquiries, protecting LIFEGUARD’s business, people and systems, conducting lawful client and candidate assessment, preventing fraud or misuse, and ensuring that sensitive engagements are accepted and managed responsibly.
6. Special Categories of Personal Data and Sensitive Information
LIFEGUARD does not seek sensitive personal data through the website unless it is necessary, lawful and appropriate to a clearly defined purpose.
Sensitive information may include data relating to health, biometric data, criminal allegations or convictions, political opinions, trade-union membership, religious beliefs, racial or ethnic origin, sex life or sexual orientation, as well as other information subject to heightened legal protection.
Where such information is necessary in connection with a recruitment process, legal obligation, security-sensitive role, professional engagement or legal claim, LIFEGUARD will process it only where permitted by applicable law and only to the extent necessary.
Depending on the circumstances, this may require:
- your explicit consent;
- a legal obligation or employment-law basis;
- the establishment, exercise or defence of legal claims;
- substantial public-interest grounds recognised by law;
- another lawful and appropriate basis available under the applicable legal framework.
LIFEGUARD may decline to accept, delete, restrict or redirect sensitive information received through an inappropriate or insecure communication channel.
7. Cookies, Similar Technologies and Website Analytics
LIFEGUARD uses only those cookies and similar technologies that are necessary for the secure and effective operation of the website, unless you have provided consent for additional technologies.
Necessary technologies may be used for purposes such as:
- security and fraud prevention;
- load balancing and website functionality;
- preserving essential user settings;
- protecting forms, communications or administrative functions;
- recording cookie-consent preferences.
LIFEGUARD does not use advertising cookies, social-media tracking pixels or behavioural marketing technologies unless these are specifically disclosed through the Cookie Notice and activated only in accordance with applicable consent requirements.
Where non-essential cookies, analytics tools or similar technologies are introduced, LIFEGUARD will provide clear information through a separate Cookie Notice and, where required, obtain your consent before such technologies are activated.
You may manage or withdraw cookie preferences through the website’s cookie-management mechanism, where available, or through your browser settings. Disabling certain necessary cookies may affect the functionality or security of the website.
8. How We Share Personal Data
LIFEGUARD does not sell personal data.
We may share personal data only where necessary, lawful and proportionate, including with:
- LIFEGUARD entities involved in the relevant activity or mandate;
- carefully selected professional advisers, including legal, tax, compliance, insurance or audit advisers;
- technology, hosting, security, document-management, communications and administrative service providers;
- recruitment, verification, screening or assessment providers, where relevant and lawful;
- regulated, licensed or jurisdictionally qualified specialist providers;
- clients, prospective clients or authorised representatives, where necessary and appropriate;
- governmental, regulatory, law-enforcement or judicial authorities, where legally required or permitted;
- insurers, professional advisers or other parties involved in the establishment, exercise or defence of legal claims;
- a purchaser, successor or professional adviser in connection with a corporate restructuring, merger, acquisition or transfer of business, subject to appropriate confidentiality and legal safeguards.
Where third parties process personal data on LIFEGUARD’s behalf, LIFEGUARD seeks to ensure that appropriate contractual, confidentiality, security and data-protection obligations apply.
Where a third party acts as an independent controller, its own privacy notice and legal obligations will apply.
9. International Transfers
LIFEGUARD may process, access or disclose personal data across borders where this is necessary for website operation, internal administration, recruitment, communications, the delivery or assessment of professional services, use of specialist providers or legal and compliance purposes.
This may include transfers between or access from the European Economic Area, Austria, Malta, Switzerland, the United Kingdom and other jurisdictions relevant to a particular matter.
Where applicable privacy law treats a transfer as an international transfer, LIFEGUARD will seek to use an appropriate lawful transfer mechanism. Depending on the relevant jurisdictions, this may include:
- a finding that the destination country provides an adequate level of protection;
- standard contractual clauses or equivalent contractual safeguards;
- the United Kingdom International Data Transfer Agreement or an approved addendum;
- appropriate supplementary technical, organisational or contractual measures;
- a recognised exception or derogation, where available and appropriate under applicable law.
The protections available in another jurisdiction may differ from those available in your country of residence. LIFEGUARD will take reasonable steps to ensure that any transfer is carried out in accordance with applicable law and subject to safeguards appropriate to the nature and sensitivity of the information.
You may contact the Privacy Office for further information about the principal transfer mechanisms relevant to your personal data.
10. Data Retention
LIFEGUARD retains personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, professional, accounting, insurance, security, recordkeeping and legal-claim requirements.
Retention periods will depend on the nature of the information, the purpose of processing, the sensitivity of the matter, applicable laws and the existence of potential or actual disputes.
Unless a longer period is required or justified, LIFEGUARD generally applies the following approach:
| Category | Indicative retention approach |
|---|---|
| Website-security logs and technical records | Retained for 90 days, unless longer retention is necessary to investigate security incidents, misuse or legal issues |
| General correspondence not resulting in an engagement | Retained for up to 12 months after closure of the matter, unless a longer period is required or justified |
| Private Office enquiries and preliminary mandate records | Retained for the duration of the assessment and thereafter for 10 years, taking account of conflict, compliance, legal and professional-risk requirements |
| Recruitment applications | Retained for the duration of the recruitment process and generally for 12 months thereafter, unless longer retention is required by law, necessary for legal claims, or separately agreed |
| Successful-candidate records | Retained in accordance with the applicable employment, payroll, compliance and personnel-retention requirements |
| Cookie-consent records | Retained for the period necessary to demonstrate and manage consent, in accordance with applicable law and configuration settings |
| Legal, compliance, dispute or investigation records | Retained for as long as reasonably necessary to comply with legal obligations or establish, exercise or defend legal claims |
At the end of the relevant retention period, personal data will be securely deleted, anonymised or otherwise removed from active use, unless continued retention is required or permitted by law.
11. Security of Personal Data
LIFEGUARD recognises that the information it receives may be commercially sensitive, operationally significant or personally confidential.
We seek to implement technical, organisational and procedural measures appropriate to the nature, sensitivity and foreseeable risks associated with the personal data concerned.
These measures may include, where appropriate:
- access controls and need-to-know restrictions;
- authentication and account-security measures;
- secure hosting and system-administration arrangements;
- encrypted communication or document-handling solutions;
- logging, monitoring and incident-response procedures;
- staff, adviser and provider confidentiality obligations;
- controlled retention and deletion procedures;
- supplier assessment and contractual safeguards;
- periodic review of relevant security measures.
No method of transmission, storage or processing can be guaranteed to be entirely secure. You should therefore avoid transmitting highly sensitive information through ordinary email or other unencrypted channels until an appropriate secure communication arrangement has been agreed.
12. Automated Decision-Making
LIFEGUARD does not use personal data collected through the website to make decisions based solely on automated processing where those decisions produce legal effects or similarly significant effects for individuals.
LIFEGUARD may use reasonable technical tools to identify spam, malicious activity, suspicious website traffic or security threats. Such measures are intended to protect the website, communications and users and are not designed to make substantive decisions about individuals.
Where automated assessment or profiling is used in a manner that is subject to specific legal requirements, LIFEGUARD will provide additional information where required.
13. Your Rights
Subject to applicable law and the circumstances of the request, you may have the right to:
- request access to personal data concerning you;
- request correction or completion of inaccurate or incomplete personal data;
- request deletion of personal data in certain circumstances;
- request restriction of processing in certain circumstances;
- object to processing based on legitimate interests or direct marketing;
- request portability of personal data, where applicable;
- withdraw consent where processing is based on consent;
- request information about relevant recipients, categories of recipients or international transfers;
- raise concerns about the handling of your personal data;
- complaint with a competent data-protection authority.
These rights are not absolute. For example, LIFEGUARD may need to retain certain information to comply with legal obligations, protect confidentiality, preserve legal privilege, establish or defend legal claims, protect the rights of others, maintain security or comply with lawful restrictions applicable to sensitive professional, investigative or security-related work.
To protect confidentiality and prevent unauthorised disclosure, LIFEGUARD may request information necessary to verify your identity before responding to a rights request.
To exercise your rights, please contact:
Privacy Office
Email: privacy@lifeguard.org
14. Complaints and Supervisory Authorities
LIFEGUARD encourages individuals to contact the Privacy Office first so that concerns can be considered promptly and appropriately.
You may also have the right to lodge a complaint with the competent data-protection authority in your place of residence, place of work or the place of the alleged infringement.
Relevant authorities may include:
Austria
Austrian Data Protection Authority
Österreichische Datenschutzbehörde
Malta
Information and Data Protection Commissioner
Office of the Information and Data Protection Commissioner
Switzerland
Federal Data Protection and Information Commissioner
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter
United Kingdom
Information Commissioner’s Office
For individuals in the European Economic Area, the competent supervisory authority may also be the authority in the relevant EEA Member State.
15. Direct Marketing
LIFEGUARD does not use website-related personal data for unsolicited direct marketing without an appropriate lawful basis.
The website is not intended to operate as a general marketing, newsletter or promotional-distribution platform. Where LIFEGUARD introduces any marketing communications, subscription service or event-invitation process, the relevant privacy information and, where required, consent arrangements will be made available at that time.
You may object to direct marketing at any time by contacting the Privacy Office.
16. Careers and Recruitment Privacy
LIFEGUARD’s Careers section is intended for defined and actively published appointments.
LIFEGUARD does not maintain an open speculative-application database unless it expressly states otherwise in connection with a particular recruitment exercise.
Information submitted for a current appointment will be used only for purposes connected with that application, related recruitment administration, legal and compliance requirements, and the protection of LIFEGUARD’s legitimate interests.
Where an applicant is unsuccessful, LIFEGUARD will retain application information only for the period stated in this Notice or otherwise notified to the applicant, unless:
- the applicant has separately agreed to a longer retention period;
- continued retention is required by law;
- the information is necessary for the establishment, exercise or defence of legal claims; or
- another lawful basis applies.
Additional recruitment notices may be provided where a role is subject to particular legal, employment, licensing, security, immigration, vetting or operational requirements.
17. Children and Minors
The website and LIFEGUARD’s professional services are not directed to children.
LIFEGUARD does not knowingly collect personal data from children through the website. If you believe that a child has provided personal data to LIFEGUARD without appropriate authority, please contact the Privacy Office so that the matter can be reviewed.
18. Third-Party Websites
The website may contain links to third-party websites or resources.
LIFEGUARD is not responsible for the privacy practices, content, security or availability of third-party websites. You should review the privacy notice of any third-party site before providing personal data through it.
19. Changes to This Privacy Notice
LIFEGUARD may update this Privacy Notice from time to time to reflect changes in legal requirements, website functionality, business practices, service providers, security measures or the way in which personal data is processed.
The most current version will be published on the website together with the “Last updated” date.
Where a change is material and notification is required by law, LIFEGUARD will take appropriate steps to provide additional notice.
20. Contact
For questions, concerns or requests relating to this Privacy Notice or LIFEGUARD’s handling of personal data, please contact:
Privacy Office
LIFEGUARD Ltd.
Email: privacy@lifeguard.org
Postal address: Gußhausstraße 6, 1040 Vienna
Please do not send highly sensitive, classified, legally privileged or security-restricted information through ordinary email before an appropriate secure communication channel has been agreed.