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Privacy Policy

​​​1. Introduction

Cornish-Vaughan Associates is an independent recruitment agency based in the United Kingdom. I am committed to handling personal data fairly, lawfully, and transparently, in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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For data protection purposes, Jen Cornish-Vaughan is the data controller.

Contact details:
Cornish-Vaughan Associates

 

2. Personal Data I Collect

I may collect and hold:

Candidates

  • Name, contact details, and location

  • CVs, employment history, education, and qualifications

  • Interview notes and suitability assessments

  • Salary expectations and job preferences

  • Right-to-work information

  • References (where relevant)

  • Equality and diversity information (only if you choose to provide it)

Clients (Employers)

  • Names and contact details of business representatives

  • Job role details and recruitment requirements

  • Communications and contractual information

Website Users

  • IP address and basic usage data through cookies (see section 9)

 

3. How Personal Data Is Used

Personal data is used to:

  • Provide recruitment and job-matching services

  • Introduce candidates to potential employers

  • Communicate about job opportunities and recruitment activity

  • Carry out right-to-work and compliance checks

  • Meet legal and regulatory obligations

  • Run and improve my business

 

4. Lawful Basis for Processing

Under UK GDPR, personal data is processed on the basis of:

  • Consent – where you have given clear permission

  • Contract – where processing is needed to take steps before or during a contract

  • Legal obligation – such as right-to-work checks

  • Legitimate interests – to operate a recruitment business fairly and effectively

Where special category data is processed (e.g. diversity information), this is done in line with UK GDPR safeguards and only where appropriate.

 

5. Sharing Personal Data

Personal data may be shared with:

  • Prospective employers for recruitment purposes

  • Background checking or right-to-work service providers

  • IT systems and recruitment software providers

  • UK authorities where legally required (e.g. HMRC or the Home Office)

Personal data is never sold.

 

6. Data Transfers Outside the UK

Personal data is mainly processed within the UK. If data is transferred outside the UK, appropriate safeguards will be in place, such as International Data Transfer Agreements (IDTAs).

 

7. Data Retention (ICO-Aligned)

Data is kept only for as long as necessary and reviewed regularly.

  • Candidate data:
    Retained for up to 12 months from the last meaningful contact.
    This aligns with ICO guidance for recruitment businesses and allows time for future opportunities. Consent will be refreshed if data is kept longer.

  • Client data:
    Retained for the duration of the working relationship and for up to 6 years afterwards to meet contractual, accounting, and legal obligations.

  • Right-to-work records:
    Retained in line with Home Office requirements (typically 2 years after employment ends, where applicable).

Data may be kept longer where required to establish, exercise, or defend legal claims.

 

8. Your Rights

You have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion of your data

  • Object to or restrict processing

  • Request data portability

  • Withdraw consent at any time

Requests can be made by emailing jen@cornish-vaughanassociates.co.uk.

You also have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk.

 

9. Cookies

The website may use cookies to ensure it works properly and to understand how visitors use it. Cookie preferences can be managed through your browser settings.

 

10. Data Security

Appropriate technical and organisational measures are in place to protect personal data from unauthorised access, loss, or misuse.

 

11. Changes to This Policy

This Privacy Policy may be updated from time to time. Any changes will be posted on the website with a revised date.

 

12. Contact

If you have any questions about this policy or how your data is handled, please contact:

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