The Step-by-Step Guide to GDPR Compliance for Small Recruitment Firms

In today’s data-driven recruitment world, protecting candidate information isn’t just good practice — it’s the law. Whether you're a solo recruiter or a growing agency with hundreds of employees, your firm is responsible for safeguarding the personal data you collect and store.

The UK GDPR applies to all businesses, regardless of size, if they process personal data — which every recruitment firm does daily.

At RockSec360, we work closely with recruitment companies to help them reduce data protection risk, meet their legal obligations, and demonstrate accountability. Here’s a practical roadmap your agency can follow to work toward full GDPR compliance.

Step-by-Step GDPR Compliance Guide for Recruitment Agencies

1. Appoint a GDPR Lead

Designate someone to be responsible for GDPR compliance who is often the founder, operations manager, or a Virtual Data Protection Officer (vDPO).

They’ll:

• Coordinate data protection activities

• Liaise with the ICO (Information Commissioner’s Office)

• Maintain documentation and respond to data requests

2. Map Your Data Flows

Start by understanding what personal data you collect and where it lives:

• CVs, contact info, ID, job history

• Stored in Recruitment specialist CRMs e.g. Bullhorn or Vincere, email inboxes, shared folders (Google Drive, OneDrive, Dropbox)

Track:

• Why you’re collecting it? 

• How long you keep it?

• Who has access to it?

3. Document Key GDPR Policies

You’ll need clear written policies to demonstrate compliance. These include:

• Privacy Policy

• Data Protection Policy

• Data Retention Policy

• SAR (Subject Access Request) Procedure

• Data Breach Response Plan

• Record of Processing Activities (ROPA)

4. Secure Your Systems and Devices

Technical controls are critical. You must:

• Encrypt staff laptops and phones 

• Enable Multi-Factor Authentication (MFA) on CRM, email, and cloud apps

• Patch and protect devices with antivirus, malware and ransomware software

• Back up sensitive data securely 

• Use DLP (Data Loss Prevention) to monitor for unauthorised downloads or sharing

5. Ensure Your Suppliers Are Compliant

You must ensure every tool or third party that processes candidate data is GDPR-compliant.

Steps to take:

• Review vendors e.g.CRM and cloud storage

• Sign Data Processing Agreements (DPAs)

• Check their GDPR credentials and audit logs

6. Train Your Staff

Your team needs to understand GDPR and how to handle personal data correctly.

• Run GDPR & phishing training regularly on an ongoing basis 

• Train new hires on your data protection policies

• Run phishing simulations to test awareness

7. Implement Retention and Deletion Workflows

Don’t keep candidate data forever.

• Set a standard retention period e.g. 24 months of inactivity

• Configure automatic deletion or archiving in CRM and email

• Log deletions for compliance

8. Prepare for Data Rights Requests

You must be able to respond to:

• Subject Access Requests (SARs)

• Requests for correction, deletion, or portability

You have 30 days to respond and must keep a record of all requests.

9. Monitor and Review Regularly

GDPR compliance is ongoing, not a one-off exercise. 

• Review your policies at least annually

• Conduct internal audits

• Monitor security logs e.g., failed logins, sensitive data export attempts

Get Help from RockSec360

We act as your outsourced cybersecurity and compliance team — tailored for recruiters.

✅ GDPR documentation
✅ Staff training and phishing simulations
✅ Device encryption, patching, and endpoint protection
✅ Secure email and cloud tools
✅ DLP, backups, and breach response
✅ Cyber Essentials certification support

In Summary: Your GDPR Compliance Roadmap

📅 Need Help Getting Started?

Book a free GDPR compliance check-up with RockSec360
Let us show you where your risks lie — and how to fix them.