Recruitment agencies handle a lot of personal data every day: CVs, right-to-work documents, references, shift availability, timesheets, bank details, and sometimes health-related information (especially in care and nursing). GDPR can sound like it’s going to add extra admin, but done properly it actually reduces risk and makes your day-to-day smoother.
Here are practical steps you can take to protect data without turning your team into full-time paperwork chasers.
1) Know what data you hold (and why)
Start simple: list the types of data you collect and where it sits.
Typical places include:
- emails and attachments (CVs, certificates)
- shared drives and spreadsheets
- WhatsApp/SMS screenshots
- recruitment software, timesheets, invoicing
- paper copies in the office
Then write down why you keep each type (for example: “to place candidates into shifts” or “to invoice clients”). This gives you a clear view of what matters, and what’s just clutter.
2) Be clear on your lawful basis
In recruitment, you’ll usually rely on one (or more) of these:
- Contract (you need data to deliver the service)
- Legal obligation (right to work checks, tax/payroll records)
- Legitimate interests (running a recruitment business)
- Consent (best used sparingly, and only where it truly fits)
The goal is not to write an essay — it’s to be able to answer, in plain English: “Why are we collecting this, and what allows us to?”
3) Collect less, and collect it later
A big GDPR win is data minimisation: only collect what you need, and only when you need it.
Examples:
- Don’t collect bank details until someone is ready to work.
- Don’t request every certificate on day one if it’s not required for the role.
- Avoid “just in case” fields on forms.
Less data means less risk, fewer breaches, and less admin.
4) Set retention rules (and actually follow them)
Most agencies keep data forever because nobody has time to clean it up. That’s risky.
Create simple retention rules:
- “Unsuccessful candidates: delete after X months”
- “Placed staff payroll records: keep for X years”
- “Client contact details: review annually”
Even if you start with just two categories, it’s better than “everything forever”. If you can automate archiving/deletion through your systems, even better.
5) Lock down access: role-based permissions
Not everyone needs access to everything.
A practical approach:
- Recruiters: candidate profiles, compliance documents (as needed)
- Payroll: bank details and timesheets
- Finance: invoices and payment status
- Managers/owners: reporting and audits
The principle is simple: give people the minimum access needed to do their job. If your platform stores data on your own server and you control who accesses it, that supports this approach.
6) Secure the “everyday” channels
Most data leaks are boring, not dramatic.
Tighten up these common weak spots:
- Stop sending documents over personal WhatsApp accounts.
- Use secure links rather than attachments where possible.
- Make sure laptops and phones are password-protected (and lock quickly).
- Turn on multi-factor authentication for email and key systems.
If your team regularly shares documents, use a proper upload process rather than “send me a photo of it”.
7) Use a single system for documents, shifts, and timesheets (where possible)
The more tools you juggle, the more copies of data you create.
A single platform that covers things like shift management, timesheets, document uploads, invoicing/payroll, and reporting reduces duplication and helps you keep a clean audit trail.
This is how you stay fast and compliant: fewer spreadsheets, fewer screenshots, fewer “final_final_v3” files.
8) Get your supplier contracts right (processors)
If you use software providers, cloud storage, payroll services, or outsourced IT, you need the right agreements in place (often called data processing agreements).
A quick checklist:
- Who is the data controller vs processor?
- Where is the data stored?
- How is it backed up?
- What happens if there’s a breach?
If a supplier can’t answer these clearly, that’s a red flag.
9) Prepare for subject access requests (SARs) now
People have the right to request a copy of the data you hold about them.
You don’t want to scramble when it happens. Set a basic internal process:
- Who receives the request?
- How do you verify identity?
- How do you export the data?
- Who checks it before sending?
If your data is spread across emails and spreadsheets, SARs become slow and stressful. If it’s centralised, they’re manageable.
10) Have a breach plan you can actually follow
A breach might be a lost phone, an email sent to the wrong person, or a hacked password.
Write a short plan:
- Contain it (change passwords, revoke access)
- Assess risk (what data, whose data, how sensitive?)
- Record it
- Notify if required (and notify affected people if there’s high risk)
The key is speed and clarity, not panic.
11) ICO registration (UK recruitment agencies must be registered)
If you operate a recruitment agency in the UK and handle personal data (which you do), you’ll almost always need to register with the ICO (Information Commissioner’s Office) and pay the data protection fee.
This is separate from “being GDPR compliant” day-to-day — it’s a basic legal requirement for many organisations that process personal information. Recruitment businesses typically process large volumes of candidate and worker data, so ICO registration is usually expected.
Practical steps:
- Check your requirement: Most agencies will need to pay the ICO data protection fee, but your tier depends on size and turnover.
- Register and keep proof: Once registered, keep a record of your ICO registration number and renewal date.
- Make it visible: Add your ICO registration details to your website footer, privacy policy, and (if relevant) candidate onboarding docs.
- Renew on time: Missing renewals is a common and avoidable compliance issue.
Why it matters:
If something goes wrong — a complaint, a breach, or a client due diligence check — being registered helps demonstrate that you’re taking data protection seriously and following UK compliance basics.
Quick answers
What personal data do recruitment agencies hold?
Usually CVs, contact details, work history, compliance documents, shift records, timesheets, and sometimes bank/payroll info.
How can agencies be GDPR compliant without slowing down?
Centralise data, collect less upfront, automate retention, restrict access by role, and use secure document workflows.
What’s the biggest GDPR risk in recruitment?
Data sprawl: duplicates in emails, spreadsheets, WhatsApp, and shared drives with unclear access and retention.
Final takeaway
GDPR doesn’t have to be a brake on growth. If you cut down the number of places data lives, tighten access, and build simple habits (like collecting less and deleting on time), you’ll protect the business and free up your team’s time.