AGM Construction Recruitment

Privacy Notice

Last updated: 22 October 2026

Who this notice applies to

This notice explains how ABBA Direct Ltd, trading as AGM Construction Recruitment (‘AGM’, ‘we’, ‘us’ or ‘our’), handles personal information about candidates and work-seekers, temporary workers and contractors, clients and business contacts, referees, and people who contact us.

1. Who we are and how to contact us

AGM Construction Recruitment is the trading name of ABBA Direct Ltd, a limited company. For the recruitment and labour-supply activities described in this notice, ABBA Direct Ltd will generally act as a data controller: we decide why and how the relevant personal information is used. Other organisations involved in a placement, such as a client, umbrella company or payroll provider, may have their own data-protection responsibilities.

Privacy enquiries: anabellew@agmconstructionrecruitment.co.uk
General enquiries: grahame@agmconstructionrecruitment.co.uk

Registered office: 73 The Granary, Wynyard, Billingham, Cleveland, TS22 5QG.
Company number: 14045632.

2. What information we collect and where it comes from

Candidates and workers

Depending on the role and stage of recruitment or assignment, we may collect your name, contact details, address, CV, work history, skills, trade and experience; qualifications, training records, cards and certificates; availability, preferred locations and rates; references; relevant correspondence and recruitment notes; and information needed to arrange introductions, assignments, timesheets or payments.

Where required for a particular role or engagement, we may also handle identity and right-to-work information, evidence of relevant qualifications or authorisations, and information needed for legal or contractual compliance. We only seek health, adjustment or other special-category information where there is a defined and lawful reason. Criminal-offence information is handled only where the relevant legal conditions permit it.

Clients and business contacts

We may collect names, job titles, business contact details, employer and site information, recruitment or labour requirements, quotations, contracts, assignment details, invoices, payment records and related correspondence.

Sources

Information may come directly from you through our website, forms, CVs, calls, emails or other correspondence. We may also obtain information from referees, clients, people who refer you to us, recruitment platforms and job boards, professional networking sites, public sources, and services used for recruitment or business contact sourcing.

When we obtain information indirectly, we provide the privacy information required by law, normally within one month and sooner where required.

3. Why we use information and our lawful bases

We use information for specific recruitment, business and legal purposes. The lawful basis depends on the circumstances and the particular processing activity.

Recruitment and matching: To assess experience and suitability, maintain relevant candidate records, identify potential roles and match people to client requirements. We generally rely on legitimate interests or, where applicable, steps taken at your request before entering into a contract.

Introductions and placements: To share relevant candidate information with a prospective client, arrange interviews and assignments, and administer the recruitment relationship. The basis may be legitimate interests, pre-contractual steps or contractual necessity, depending on the situation.

Assignment administration and payment: To handle assignment details, timesheets, invoicing, payment-related administration and communications. The basis may be contractual necessity, legitimate interests or legal obligation, as applicable.

Legal and regulatory compliance: To keep records and carry out checks required by employment-agency, right-to-work, tax, accounting, health and safety or other applicable rules. We rely on legal obligation where a specific legal duty applies.

Security, disputes and claims: To protect business systems, prevent or investigate misuse, maintain appropriate records, and establish, exercise or defend legal claims. We may rely on legitimate interests or legal obligation.

Business contact and marketing: To contact business representatives about relevant recruitment services and opportunities where permitted. We assess the applicable data-protection and electronic-marketing rules for each communication method and recipient type.

Where we rely on legitimate interests, those interests may include running our recruitment business, identifying suitable candidates, responding to client requirements, maintaining appropriate business records and protecting our operations. We consider the impact on individuals and their rights when relying on this basis.

4. Recruitment communications and promotional marketing

Contact about a specific role, application, introduction, assignment or existing business relationship is different from promotional marketing. Registering with AGM or providing a CV does not, by itself, amount to blanket permission to send unrelated marketing.

We assess whether marketing communications are permitted under applicable rules, including the Privacy and Electronic Communications Regulations (PECR). The rules can differ for individual subscribers and corporate subscribers, and other data-protection requirements may also apply. We will identify ourselves appropriately and provide a suitable way to opt out where required.

You can object to the use of your information for direct marketing at any time. We will stop using it for that purpose. We may retain a minimal suppression record so we can respect your preference. If we rely on consent for a particular activity, you may withdraw it at any time; this does not affect processing that was lawful before withdrawal.

5. Who receives your information

We share information only where relevant to the purpose and appropriate in the circumstances. Recipients may include:

Prospective employers and recruitment clients, to consider a candidate for a role or arrange an assignment.
Clients, site representatives and authorised contacts, where relevant to site access, qualifications, safety or assignment administration.
Umbrella companies and payroll providers, where involved, to arrange onboarding, administer an engagement and process payments. This may include a worker’s preferred umbrella company, where agreed for the assignment.
Referees and qualification or credential verification providers, where relevant and appropriate.
Professional advisers, insurers, banks, regulators, public authorities or law-enforcement bodies where necessary for legal, financial, regulatory or dispute-related purposes.
Technology and business service providers that support email, CRM, website forms, document storage, contact sourcing, workflow automation or communications.

Where an umbrella company is involved, it obtains and retains passport and right-to-work documentation before work commences. AGM receives onboarding progress updates and confirmation that the required checks are complete, rather than copies of those documents from the umbrella. The provider’s own privacy notice explains how it handles information it holds.

We do not send every category of information to every recipient. We aim to disclose only information relevant to the particular role, assignment or purpose. A client, umbrella company or payroll provider may act as a separate data controller for its own activities and should provide its own privacy information where required.

6. International processing

AGM uses Google Workspace for business email and related functions, and HubSpot for CRM and related business activity. AGM’s HubSpot account is primarily hosted in the European Union (Germany). This does not mean that all processing or storage takes place exclusively in Germany or the European Union. Depending on the service, account settings and particular activity, personal information may be stored, accessed or processed outside the United Kingdom.

The providers’ data-processing terms describe the safeguards for relevant international transfers. HubSpot’s Data Processing Agreement provides for Standard Contractual Clauses with the UK International Data Transfer Addendum for relevant UK transfers, and Data Privacy Framework arrangements where applicable. Google’s Cloud Data Processing Addendum provides for processing in countries recognised as providing adequate protection and, for relevant transfers elsewhere, an applicable alternative transfer solution or Standard Contractual Clauses. The mechanism that applies depends on the organisations involved, the destination and the particular processing.

Further details are available in HubSpot’s Data Processing Agreement and Google’s Cloud Data Processing Addendum. These provider arrangements do not remove AGM’s own data-protection responsibilities. We review the arrangements relevant to our use of each service and carry out any assessment required for transfers for which we are responsible.

Contact anabellew@agmconstructionrecruitment.co.uk for further information about the safeguards relevant to your information or to request a copy. We will review the notice and relevant arrangements when introducing or materially changing a service.

7. How long we keep information

We do not keep personal information indefinitely. We retain it for as long as reasonably necessary for the purpose for which it was collected, taking account of applicable legal requirements, the nature of the record, the relevant relationship and the need to resolve disputes or demonstrate compliance.

Recruitment and hirer records: Records required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003 are kept for at least one year from creation and, for relevant work-seeker and hirer application records, at least one year after AGM last provided services to that applicant. The Regulations provide an exception for specified application records where no action is taken.

Inactive or unsuccessful candidates: As a general review rule, we review inactive or unsuccessful candidate records 12 months after the last meaningful recruitment activity. We delete or anonymise information when it is no longer needed, unless a legal, regulatory, dispute-related or documented continuing recruitment reason justifies keeping it. Applicable statutory retention requirements take priority. This is a review point, not automatic deletion after 12 months.

Client and business contacts: We review records when a relationship or active discussion ends and delete or anonymise information when it is no longer needed, subject to applicable legal obligations and legitimate needs such as resolving disputes.

Accounting, invoices and payment records: Company accounting and tax records are generally retained for at least six years where required by applicable company and tax rules, with the precise period depending on the record and any applicable exception.

Right-to-work and identity evidence: Where an umbrella company is involved, it obtains and retains passport and right-to-work document copies under its own responsibilities. AGM receives progress updates and confirmation of completed checks, rather than document copies from the umbrella. We retain our own onboarding confirmations and other relevant records for as long as necessary for assignment administration, applicable legal requirements and documented dispute or compliance needs. Where AGM independently needs to hold identity or right-to-work evidence, its retention depends on the purpose, applicable legal requirements and AGM’s role. We do not automatically retain copies indefinitely.

Marketing preferences and objections: We retain a minimal suppression record for as long as reasonably necessary to ensure that an objection or opt-out is respected.

Privacy requests, complaints and legal claims: We retain records for the period reasonably necessary to respond, demonstrate compliance and deal with related legal or regulatory matters.

AGM will maintain an internal retention schedule and review records periodically. When information is no longer required, it is securely deleted or anonymised where practicable, including from relevant systems and service providers in accordance with their capabilities and contractual terms. Backups may retain information for a limited period before it is overwritten.

8. Security and systems

AGM uses Google Workspace for business email and related functions, and HubSpot CRM for recruitment, client and business records. We will assess data-protection and security arrangements before introducing or reactivating another service that will handle personal information.

Within AGM, access to candidate and client records is restricted to the business owner. Access to our accounts is protected by authentication. Google Workspace uses two-step verification. Technology providers may process information under their service arrangements. No system or transmission method can be guaranteed completely secure.

AGM will review active integrations and supplier access when a tool is no longer needed. We take appropriate steps to investigate and respond to suspected personal-data breaches, including making notifications required by law.

9. Health, other sensitive information and criminal-offence data

We do not routinely need health information or other special-category information for ordinary recruitment. Where such information is necessary, for example to consider a workplace adjustment or meet a specific legal requirement, we identify a lawful basis under Article 6 of the UK GDPR and a separate condition under Article 9 before processing it. Where required, we also meet additional conditions and safeguards in the Data Protection Act 2018. We limit access and retention appropriately.

Criminal-offence information is subject to separate legal restrictions. AGM will only collect or use it where the relevant legal authority and safeguards apply. We will not request criminal-record information routinely without first establishing that it is lawful and necessary.

10. Automated decision-making and profiling

AGM does not make recruitment decisions solely by automated means. Candidate suitability, offers and placement decisions involve meaningful human assessment by the business owner. If we introduce a system that makes decisions solely by automated processing and has legal or similarly significant effects, or undertake relevant profiling, we will first assess applicable legal requirements, safeguards and information duties and update this notice as necessary.

11. Your data-protection rights

Depending on the circumstances and applicable legal conditions, you may have the right to:

Request access to your personal information.
Ask us to correct inaccurate or incomplete information.
Request erasure where the legal conditions are met.
Request restriction of processing in certain circumstances.
Receive certain information in a portable format, where the right applies.
Object to processing based on legitimate interests or another applicable ground.
Object to direct marketing at any time; this right is absolute for processing carried out for direct-marketing purposes.
Withdraw consent where we rely on consent, without affecting the lawfulness of processing before withdrawal.

These rights are subject to legal conditions and exceptions; not every right applies in every situation. To make a request, email anabellew@agmconstructionrecruitment.co.uk and explain what you need. We may need to verify your identity before responding. We normally respond within one month, subject to any lawful extension or other applicable rule.

You can complain to AGM about how we handle your personal information by emailing the address above or writing to our registered office. We will acknowledge data-protection complaints within 30 days, investigate without undue delay, keep you informed of progress and explain the outcome.

You can complain to the Information Commissioner’s Office (ICO), the UK data-protection regulator, at https://ico.org.uk/. You do not have to contact AGM first, although we welcome the opportunity to address your concern.

12. Information you need to provide

Some information is necessary to assess suitability for a role, make an introduction, arrange an assignment, complete required checks or meet legal obligations. If you do not provide information that is genuinely necessary, AGM may be unable to consider you for a particular role, introduce you to a client, arrange an assignment or complete the relevant checks. We will explain when information is required and the likely consequences of not providing it where appropriate. We will not describe optional information as compulsory without a valid reason.

13. Cookies and website technologies

Cookies are small files stored in your browser. Our HubSpot-hosted website uses cookies for website operation, security and remembering cookie choices. Optional analytics cookies may also be used, depending on your choices and the services enabled.

Your choices

Our cookie banner offers ‘Cookie settings’, ‘Accept all optional cookies’ and ‘Reject all optional cookies’. You can choose which optional categories to accept when the banner appears. Necessary cookies support website operation and security.

To review or change your cookie choices, select Cookie Settings in the website footer to reopen the cookie banner.

You can also remove stored cookies or block cookies using your browser settings. Removing cookies can remove remembered preferences, and blocking cookies may affect website functions. If you need help with your preferences, contact anabellew@agmconstructionrecruitment.co.uk.

Website operation and preferences

__hs_cookie_cat_pref (HubSpot): remembers your cookie-category preferences. This is a persistent cookie, which remains beyond the browsing session until it expires or is removed.
_cfuvid (Cloudflare): supports rate limiting by distinguishing visitors who share an IP address. It is a session cookie.

Optional analytics

The following are HubSpot’s standard analytics cookies. They may be used when the relevant tracking is enabled and consent has been given. The lifetimes below are those documented by HubSpot.

__hstc: records visitor-tracking history; six months.
hubspotutk: identifies a visitor and helps match form submissions to contact records; six months.
__hssc: tracks browsing sessions; 30 minutes.
__hssrc: identifies a new browser session; ends with the session.

Previous live-chat cookies

AGM disabled its live-chat flow on 14 October 2026. If you used the website previously, your browser may retain the messagesUtk cookie, which HubSpot uses to recognise chat visitors and maintain conversation continuity. HubSpot documents a six-month lifetime. Disabling chat does not itself delete a cookie already stored in your browser; you can remove it through your browser settings.

Further cookie information

See HubSpot’s visitor-cookie documentation and Cloudflare’s cookie documentation for information about their technologies. Cookies used can vary with the website features and services enabled.

14. Changes to this notice

We may update this notice when our services, systems, legal obligations or information-handling practices change. The current version will be published on our website with an updated date. We will provide additional information or notify affected people where required.