Privacy Policy

Last updated: [Date — populate on Tony approval]

Effective from: [Date — populate on Tony approval]

1. Who we are

Tony Pugal Recruitment Ltd ("Tony Pugal Recruitment", "the agency", "we", "us") is the data controller for the personal data described in this policy.

• Company name: Tony Pugal Recruitment Ltd
• Companies House number: 06879773
• Registered office: Unity Business Centre, Roundhay Road, Leeds, West Yorkshire LS7 1AB
• Trading address: Oxford House, Oxford Row, Leeds LS1 3BE
• Telephone: 0113 226 1111
• Email: tony@tonypugalrecruitment.co.uk
• ICO registration: [Z-prefix number — populate on Tony confirmation; held until verified]

This policy explains what personal data we collect, how we use it, who we share it with, how long we keep it, and the rights you have over it. It is written in plain English. If anything is unclear, contact the founder directly on the details above.

2. Personal data we collect

2.1 If you are a worker / candidate

• Name, date of birth, address, telephone, email.
• Right-to-work documentation (passport, BRP, share code, or equivalent).
• National Insurance number.
• Bank account details (for wage payment).
• Work history, qualifications, certifications (e.g. FLT licence).
• Health information you choose to share that is relevant to placement (e.g. lifting restrictions).
• Emergency contact details.
• Pay rate, hours worked, and placement history while engaged through the agency.

2.2 If you are an employer / client

• Business name, contact name, telephone, email, site address.
• Vacancy details, shift patterns, agreed pay rates.
• Invoicing and payment information.

2.3 If you visit this website

• Pages visited and time spent (collected via Google Analytics 4 — see "Cookies" below).
• Information you submit through any contact or enquiry form.
• IP address and browser type, used solely for analytics and security purposes.

3. How we use your data and the legal basis

4. Who we share your data with

We share personal data only with the following categories of recipient, and only where necessary:

• Client employers — receiving CVs, contact details, and confirmation of right-to-work status of workers placed at their sites.
• HMRC — for PAYE, NIC, and Real Time Information returns.
• Pension providers — for auto-enrolment compliance (where applicable).
• External payroll provider — [name to be added on Tony confirmation].
• Accountants — for the agency's financial reporting.
• Banking providers — for wage and invoice payments.
• The Fair Work Agency, Gangmasters and Labour Abuse Authority, or other regulatory bodies — where lawfully required.
• The Police or HMRC fraud unit — where lawfully required.

We do not sell personal data. We do not share data with marketing partners. We do not share data with third-party recruitment platforms or aggregators.

5. International transfers

The agency operates entirely from the UK. Personal data is stored on UK and EU-located servers (Krystal Hosting, UK; Google Workspace, EU/UK regions). We do not knowingly transfer personal data outside the UK or EEA. Where any sub-processor (e.g. a security service) routes traffic via a third-country data centre, we rely on the UK adequacy regulations or applicable Standard Contractual Clauses.

6. How long we keep your data

7. Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Erase your data (subject to retention obligations above).
• Restrict our processing of your data.
• Object to processing based on legitimate interests.
• Data portability — receive your data in a structured, commonly used format.
• Withdraw consent at any time where we rely on consent.
• Lodge a complaint with the Information Commissioner's Office (ICO) — https://ico.org.uk/make-a-complaint/ or 0303 123 1113.

To exercise any of these rights, contact Tony Pugal directly on tony@tonypugalrecruitment.co.uk or 0113 226 1111. We will respond within one calendar month.

8. Cookies

This website uses the following categories of cookies. You can manage your preferences via the cookie banner.

• Strictly necessary — required for the site to function (session, security).
• Analytics — Google Analytics 4 (anonymised IP, 14-month retention) to understand how visitors use the site.
• Functional — remembering your cookie banner preference.

The site does not use advertising or third-party tracking cookies.

9. Security

The agency takes the following measures to protect personal data:

• Encrypted (TLS) connections to the website and to back-office systems.
• Strong access controls — only the founder and designated payroll provider have access to candidate and worker data.
• Regular software updates and security monitoring (Wordfence, server-side firewall).
• Encrypted bank-level transmission for payroll data.
• Backup procedures with off-site retention.

10. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top of the page reflects the most recent revision. Material changes will be communicated to active workers and clients by email.

11. Contact

For any data protection question, contact Tony Pugal directly:

• Email: tony@tonypugalrecruitment.co.uk
• Telephone: 0113 226 1111
• Post: Tony Pugal Recruitment Ltd, Oxford House, Oxford Row, Leeds LS1 3BE

This policy is provided in plain English in line with ICO guidance. Where there is a conflict between the plain-English description and the underlying statutory obligation, the statutory obligation prevails.