Privacy Policy

Kevin Theobald Recruitment Ltd ("We") are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person


Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Kevin Theobald Recruitment Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:

  • By email at
  • By phone on 01784 420410 or
  • By letter to Kevin Theobald Recruitment Ltd, Suite 1B, Ashford House, 41/45 Church Road, Ashford, Middlesex. TW15 2TQ

For all data matters contact Kevin Theobald, or Kim Glass our Data Protection Officer/Representative on 01784 420410

3. The purpose(s) of processing your personal data - Candidates

Please note that we may process your personal data without your knowledge or consent, in compliance with recruitment procedures, where this is required or permitted by law.

We use your personal data for the following purposes to:

  • skills match with job vacancies
  • assist job seekers in finding a position by sending your CV to our clients
  • place you in a temporary or permanent position with our clients
  • update you with new job opportunities
  • reference check your work history by contacting previous employers
  • check your right to work – criminal check if required, passport, ID
  • send you a contract and documentation if placed in a temporary position
  • use personal details for payroll, HMRC and banking when working as a temporary Agency Worker

4. The purpose(s) of processing your personal data – Clients

We use electronical and postal marketing communication to give you an update on our services and provide you with information on our candidates.

Marketing - We use the information you provide us with, such as your name and email address to keep you updated and to communicate with you regarding prospective candidates as part of the recruitment process.

Registering a job/sourcing/interviewing an applicant/job offer – we will share your company details with prospective applicants to facilitate a workforce solution.

5. What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR) –

Our lawful basis for processing your general personal data:


 Consent of the data subject; Consent form/email
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract Skills Check

Right to Work

5 year work history

Processing necessary for compliance with a legal obligation Aviation Security
Processing necessary to protect the vital interests of a data subject or another person Aviation Security
Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller Aviation Security
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject Criminal Check

Right to Work

5 year work history

 6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared between Clients and Applicants during the recruitment process.

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for a period of 5 years for work history and PAYE requirements.  Examples include: in case of any legal claims/tax, NI queries/complaints; for safeguarding purposes etc.

8. Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:

Candidate – we will be unable to process your application and assist you

with your job search

Client -           we will be unable to facilitate sourcing and placement of an


9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

Where a Candidate or Client is based overseas, data will be transferred between parties for the purpose of the recruitment process.

11. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

12. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

13. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Kevin Theobald or Kim Glass:

  • By email at
  • By phone on 01784 420410 or
  • By letter to Kevin Theobald Recruitment Ltd, Suite 1B, Ashford House, 41/45 Church Road, Ashford, Middlesex. TW15 2TQ

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.