Privacy Policy
Last updated: 30 April 2026
1. Who we are
Phoenix Gray Recruitment is a specialist construction recruitment agency. In this policy "we", "us" and "our" means Phoenix Gray Recruitment.
- Trading address: Units 4 & 5, Blue Cedars, London Road, Billericay, Essex CM12 9HS
- Registered address: Old Granary, Dunton Road, Basildon, Essex SS15 4DB
- Website: www.phoenixgrayrec.com
- Contact: Contact us
We are the data controller for personal data collected through this website and our recruitment activities. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. What personal data we collect
From jobseekers and candidates
- Name, address, email address, telephone number
- CV, work history, qualifications, and CSCS card details
- Right to work documentation (e.g. passport, visa, share code)
- National Insurance number (for payroll purposes)
- Bank details (where we are processing pay)
- References and background check results
- Availability and wage expectations
From employers and clients
- Business name, address, and company registration number
- Contact name, job title, email, and telephone number
- Vacancy details and requirements
- Billing information
From website visitors
- IP address and browser/device information (via analytics)
- Pages visited and time spent on site
- Referral source (how you arrived at the site)
- Information submitted via contact or vacancy forms
3. How we collect your data
We collect personal data:
- Directly from you when you submit a form, apply for a role, or contact us
- From job boards and CV databases where you have posted your details
- From LinkedIn and other professional networks
- Via referrals from other workers or clients
- Automatically through our website (cookies and analytics — see Section 9)
4. Why we use your data (legal basis)
We process your personal data for the following purposes and on the following legal bases:
| Purpose | Legal basis |
|---|---|
| Matching candidates to vacancies and presenting profiles to employers | Legitimate interests (recruitment services) |
| Processing payroll for temporary workers | Performance of a contract |
| Right to work checks (legal obligation) | Legal obligation |
| Sending job alerts and relevant opportunities | Legitimate interests / consent |
| Responding to enquiries via our contact form or WhatsApp | Legitimate interests / performance of a contract |
| Improving our website and understanding user behaviour | Legitimate interests / consent (analytics cookies) |
| Complying with employment law, tax, and HMRC obligations | Legal obligation |
5. How long we keep your data
- Candidate data (active): For as long as you are registered with us and for 2 years after your last contact, unless you ask us to remove it sooner.
- Right to work records: At least 2 years after the end of employment, as required by law.
- Payroll records: 6 years, as required by HMRC.
- Client contact data: For the duration of our business relationship and 6 years thereafter for accounting and legal purposes.
- Website enquiry data: 2 years from the date of enquiry.
- Website analytics data: As configured in Google Analytics (default 26 months).
6. Who we share your data with
We do not sell your personal data. We share data only where necessary:
- Employers / client companies — when presenting candidates for vacancies
- Payroll and accounting providers — for processing wages and invoices
- Background check providers — for DBS or reference checks where required
- HMRC and other regulatory bodies — where legally required
- IT and software providers — who process data on our behalf (e.g. website hosting, email)
- Google — analytics data (anonymised IP)
All third parties acting as data processors on our behalf are required to process data only on our instructions and in accordance with UK GDPR.
7. International transfers
Where data is transferred outside the UK (for example, to cloud services hosted in the US), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or an adequacy decision by the UK Secretary of State.
8. Your rights
Under UK GDPR you have the right to:
- Access the personal data we hold about you (Subject Access Request)
- Rectification of inaccurate or incomplete data
- Erasure ("right to be forgotten") where there is no lawful reason to continue processing
- Restriction of processing in certain circumstances
- Data portability — receive your data in a structured, machine-readable format
- Object to processing based on legitimate interests or for direct marketing
- Withdraw consent at any time where processing is based on consent
To exercise any of these rights, please contact us. We will respond within 30 days. There is no charge for reasonable requests.
9. Cookies
Our website uses cookies and similar technologies. You can control your cookie preferences via the banner that appears on your first visit.
Types of cookies we use
| Category | Purpose | Can be declined? |
|---|---|---|
| Essential | Required for the website to function (e.g. storing your cookie preferences) | No |
| Analytics | Google Analytics — helps us understand how the site is used (anonymised) | Yes |
Cookies set for analytics purposes are only placed after you have given consent. You can change your preferences at any time by clearing your browser cookies (which will reset the banner) or by contacting us.
10. Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Our website is served over HTTPS. Access to candidate data is restricted to authorised staff only.
11. Children's data
Our services are not directed at children under 18. We do not knowingly collect data from anyone under 18. If you believe we have inadvertently collected a child's data, please contact us immediately so we can delete it.
12. Changes to this policy
We may update this policy from time to time. The "last updated" date at the top of this page will reflect any changes. We recommend you review it periodically.
13. Complaints
If you are unhappy with how we handle your data, you have the right to complain to the UK's supervisory authority:
- Information Commissioner's Office (ICO)
- Website: ico.org.uk
- Helpline: 0303 123 1113
We would, however, appreciate the chance to address your concerns first — please contact us before escalating to the ICO.
