Legal
Privacy Policy
How we collect, use, share and protect personal information for candidates, clients and website visitors, in line with the UK GDPR and the Data Protection Act 2018.
This is a working draft prepared for a UK recruitment and staffing business. Items marked in square brackets are company specific and should be completed and reviewed before the website goes live.
1. Who we are
Fabu Group ("we", "us", "our") is a recruitment and staffing consultancy placing candidates with private households, family offices, estates, businesses, hospitality operators, nurseries, schools, care homes and other organisations.
For the purposes of UK data protection law we act as a data controller in respect of the personal information described in this notice.
[TO REVIEW BEFORE GO LIVE: insert registered legal company name, company registration number, registered office address, and ICO registration number if applicable.]
2. What personal information we collect
Candidates: name, contact details, postal address, nationality and right to work information, languages spoken, employment and education history, qualifications and certifications (for example DBS status, driving licence, first aid, childcare or care qualifications), references, salary expectations, availability, and the contents of your CV, covering notes and any supporting documents you send us.
Clients: your name, the name of your household, family office or organisation, contact details, location, and the details of the role or requirement you are discussing with us.
Website visitors: information you submit through our enquiry and registration forms, together with limited technical information such as your IP address and browser type where our hosting or analytics tools record it.
We may also receive information about you from third parties, for example referees, former employers, or a client or candidate who refers you to us.
3. Candidate CVs and applications
When you register with us or apply for a vacancy, we process your CV and application details in order to assess your suitability, discuss opportunities with you, and, with your knowledge, present you to prospective clients.
We do not send your CV or personal details to a client without first discussing that opportunity with you.
Some information you may share with us is special category data (for example health information relevant to a care role) or criminal records information (for example DBS checks). We only process such information where the law allows, normally in connection with employment obligations or safeguarding, and we keep it to the minimum necessary.
4. Client enquiries
When you make a client enquiry we use your details to respond, to understand your staffing requirement, to propose suitable candidates, and to administer any engagement between us.
Where you provide information about members of your household or organisation, please ensure you are entitled to share it with us.
5. How we use personal information and our lawful bases
Legitimate interests: to provide recruitment services, to match candidates with roles, to contact clients and candidates about relevant opportunities, to maintain our records, and to protect our business.
Contract: to perform or prepare to enter into a contract with you, for example our terms of business with a client or a placement arrangement with a candidate.
Legal obligation: to comply with right to work, safeguarding, tax, accounting and other legal requirements.
Consent: where we ask for it, for example certain marketing communications or non-essential cookies. You may withdraw consent at any time.
6. Email and telephone communications
We communicate with candidates and clients by email, telephone and messaging about live roles, applications, interviews and engagements. These communications are part of delivering our recruitment service.
We may occasionally send you information about roles or services we believe are relevant to you. You can ask us to stop at any time by emailing info@fabugroup.com.
Calls and correspondence may be recorded in our internal records for accuracy and quality purposes.
7. Cookies and website analytics
Our website uses only the cookies and storage strictly necessary to make the site function and to submit forms securely.
If we introduce analytics or marketing cookies in future, we will present a cookie notice and obtain your consent where required.
[TO REVIEW BEFORE GO LIVE: confirm whether analytics tools are in use and list them here.]
8. How long we keep information
Candidate records: normally retained for up to 3 years from your last meaningful contact with us, so that we can tell you about suitable roles, after which they are deleted or anonymised unless a longer period is required.
Client records: normally retained for the duration of our relationship and for up to 6 years afterwards to meet contractual, tax and legal record keeping requirements.
Unsuccessful enquiries and general correspondence: normally retained for up to 12 months.
[TO REVIEW BEFORE GO LIVE: confirm retention periods against your own record keeping policy.]
9. Data sharing
We may share personal information with prospective clients (candidate details, with your knowledge), with referees you nominate, with background screening and right to work providers, and with our professional advisers such as accountants and legal advisers.
We also use trusted service providers who process data on our behalf, including our website hosting, database, file storage and email providers. They act on our instructions and are bound by confidentiality and data protection obligations.
We may disclose information where required by law, by a regulator, or to protect the safety of an individual.
We do not sell personal information. Where information is transferred outside the UK, we ensure an appropriate safeguard such as UK adequacy regulations or the International Data Transfer Addendum is in place.
10. Data security
We apply appropriate technical and organisational measures to protect personal information, including access controls, encrypted transmission, restricted file storage for CVs and supporting documents, and staff confidentiality obligations.
No transmission over the internet can be guaranteed as completely secure. If you prefer, you may ask us about alternative ways to share sensitive documents.
11. Your rights under UK GDPR
You have the right to be informed, to access a copy of your personal information, to rectification, to erasure, to restriction of processing, to data portability, to object to processing carried out on the basis of legitimate interests or direct marketing, and to withdraw consent where processing is based on consent.
You also have the right not to be subject to solely automated decision making with legal or similarly significant effects. We do not make such decisions about candidates or clients.
To exercise any right, contact us using the details below. We will respond within one month, and will tell you if we need longer for a complex request.
If you are unhappy with how we have handled your information you may complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
12. How to contact us about your personal data
Email: info@fabugroup.com
Telephone: +44 7859 892420
[TO REVIEW BEFORE GO LIVE: insert postal address for data protection correspondence and, if appointed, the name and contact details of your data protection lead.]
13. Changes to this notice
We may update this notice from time to time. The date below indicates when it was last reviewed.
[TO REVIEW BEFORE GO LIVE: insert effective date and confirm this draft with your legal adviser.]
