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Home/Privacy Policy

Privacy policy.

Last updated: 11 October 2026

In this policy
  • Who we are
  • Who this policy covers
  • The law that applies
  • How we collect personal data
  • Candidates: what we hold and why
  • Clients and households: what we hold and why
  • Referees, household members and staff in training
  • Vetting, criminal record information and sensitive data
  • Right to work and visas
  • Who we share personal data with
  • Our three offices and international transfers
  • How long we keep records
  • This website: forms, hosting and cookies
  • How we protect personal data
  • Your rights
  • Complaints
  • Children
  • Changes to this policy
  • Contact
Website terms of use →Discretion policy →

Kensington Personnel places and trains household staff for private families, from offices in London, Dubai and Marbella. The work rests on people trusting us with personal information: a candidate’s career and references, a family’s home and routine. This policy sets out what we collect, why we collect it, who sees it, how long we keep it and the rights you have over it. If anything here is unclear, write to office@kensingtonpersonnel.com and we will explain.

Who we are.

Kensington Personnel is the trading name of a company registered in England and Wales. The registered company name, company number and registered office address will be published here shortly.

Kensington Personnel is the controller of the personal data described in this policy. That means we decide how and why it is used, and we answer for it in law.

We work from three offices, in London, Dubai and Marbella. All three follow this policy.

For any question about your personal data, to use one of your rights or to make a complaint, write to office@kensingtonpersonnel.com and mark your message “Data protection”.

Who this policy covers.

  • Candidates. People who apply to us, register with us or are recommended to us for a position in a private household.
  • Clients. Principals, families, family offices and the people who act for them when they ask us to find or train staff.
  • Referees. People who give a reference for a candidate.
  • Members of a household. People whose details form part of a brief, such as the children a nanny would care for.
  • Staff in training. Household staff enrolled by their employer on a Training Academy programme.
  • Visitors to this website.

The law that applies.

Our work in the United Kingdom, and the records we keep as a UK company, are governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, both as amended by the Data (Use and Access) Act 2025. As an employment agency we also keep records under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, referred to below as the Conduct Regulations 2003.

All personal data is processed by Kensington Personnel in the United Kingdom, and these laws apply to all of it. That includes enquiries from the United Arab Emirates and from anywhere else, which are processed in the United Kingdom under this policy.

How we collect personal data.

You give us personal data through this website in two ways only: through its enquiry forms and by email. The technical information that any website handles in order to load and stay secure is described under “This website: forms, hosting and cookies”.

There are three forms.

  • Hire staff asks for your name, email address, telephone number (optional), location, the role you need, and a description of your household and the role.
  • Train staff asks for your name, email address, telephone number (optional), the programme that interests you, the number of staff to be trained, your preferred delivery, and what you would like to improve.
  • Candidate apply asks for your full name, email address, telephone number, the role you are seeking, your years of experience, where you are based, and a short account of yourself.

The forms do not accept documents. CVs, certificates and identity documents come to us by email or in person, after we have replied to you. Please do not put sensitive details in the free-text boxes, such as health information, criminal record information or the names of children. There will be a better moment to share them.

Once we are working together we collect further information from you directly, in conversation, at interview and in the documents you give us, and from the referees you name. Occasionally a candidate is recommended to us by a household or by a colleague in the profession. If we hold your details from someone other than you, we tell you where they came from when we first contact you, and in any case within one month.

We do not make decisions about anyone by automated means. Every decision about a candidate or a search is made by a consultant.

We do not send newsletters or promotional mailings, and an enquiry is never added to a mailing list. We do contact registered candidates about positions that may suit them. You may ask us to stop at any time.

Candidates: what we hold and why.

What we hold

  • Identity and contact details: your name, address, telephone number, email address, nationality and, where a check requires it, your date of birth.
  • Your career: CV, employment history with any gaps explained, qualifications, training, certificates, languages and, where a role requires it, driving licence details.
  • What you are looking for: roles, locations, live-in or live-out, salary expectations and availability.
  • Our own notes: interview notes and our assessment of you against a role.
  • References: the names and contact details of your referees, and our notes of what they told us.
  • Vetting records: copies or records of identity documents, evidence of your right to work, visas, and the outcome of background checks appropriate to the role.
  • Placement records: the households you have been introduced to, any engagement that followed, the date it began, and the terms between you and us.

Why we use it, and our lawful basis

  • To consider your application, represent you and introduce you to households. This is necessary to take the steps you have asked us to take towards a position, and to carry out the terms on which we represent you (UK GDPR Article 6(1)(b)).
  • To meet our legal duties as an employment agency. Before an introduction we must confirm that you are willing to take the position. For positions that involve working with or caring for children or adults in need of care, we must also confirm your identity, experience, training, qualifications and any authorisation the role requires, obtain copies of relevant qualifications and take two references from people who are not your relatives. We must keep records of all of this. These duties come from regulations 19, 20, 22 and 29 of the Conduct Regulations 2003, and the basis is legal obligation (Article 6(1)(c)).
  • To vet in depth. We speak to former principals and managers rather than rely on a written line, we ask about gaps, and we keep notes. We do this for every role, including those where the law does not demand it. The basis is our legitimate interest, and that of the households we serve, in introducing only people who are who they say they are and who are suited to a private home (Article 6(1)(f)). We have weighed that interest against yours. You are told at the outset which checks we make, and nothing is checked without your knowledge.
  • To keep you in mind for future roles. The basis is legitimate interest, for the period given under “How long we keep records”. You may ask to be removed at any time.
  • To keep tax and accounting records and to deal with legal claims. The bases are legal obligation and legitimate interest.
  • Where we ask for your consent. We ask before approaching your current employer, and before keeping your details beyond our normal period. You may withdraw consent at any time by writing to us. Withdrawal does not affect what was done before it.

If you choose not to give us information that a check requires, we may be unable to put you forward for the role concerned. We will tell you if that is the case.

Clients and households: what we hold and why.

What we hold

  • The name and contact details of the principal and of anyone acting for them, such as a private office, a house manager or a PRO.
  • The brief: the home and its location, the role, the size of the household, routines and preferences, the existing staff, and the package offered.
  • Details of family members where the role needs them, such as the ages of children, and any health, dietary, religious or care details you choose to share.
  • Our terms of business with you, correspondence, invoices and records of payment. We take no card details through this website.
  • Records of the search and what followed: shortlists, interviews, the outcome, our check-ins after placement and anything arising under the placement assurance.
  • Training records: the programmes requested, the staff enrolled, and the results of assessments.

Why we use it, and our lawful basis

  • To carry out a search or a training programme for you. Where you are the client in your own name, this is necessary to take steps at your request before a contract and to perform our contract with you (Article 6(1)(b)). Where you act for a principal or a family office, the basis is our legitimate interest in carrying out the instruction (Article 6(1)(f)).
  • To meet our legal duties as an employment agency. Regulation 18 of the Conduct Regulations 2003 requires us to obtain enough information from a client to select a suitable candidate, including the client’s identity, the position, its location and hours, the experience and qualifications required, and the pay and notice offered. Regulation 29 requires us to keep a record of it. The basis is legal obligation (Article 6(1)(c)), which also covers our tax and accounting records.
  • To look after a placement once it is made, to honour the placement assurance and to deal with any claim. The basis is legitimate interest.
  • Sensitive details about your household. Where you give us information about the health, religion or care needs of someone in your household, we use it only to shape the brief. We rely on the explicit consent of the person the information is about (Article 9(2)(a)). For a child, that consent is given by a parent or guardian. If you tell us about another adult, please make sure they have agreed. Please share only what the role requires.

Referees, household members and staff in training.

Referees. A candidate gives us your name, your contact details and your connection to them. We use these to ask you for a reference, by telephone wherever we can, and we keep a note of what you tell us. The basis is our legitimate interest in verifying a candidate, and for roles with children or adults in need of care, our legal obligation under regulation 22. For those roles the law requires us to offer the household a copy of the reference, so we ask you to agree to that when we speak. What you tell us in confidence is treated as confidential. See “Your rights” for how this affects a candidate’s right of access.

Members of a household. We hold what the client has chosen to tell us, for the purposes of the brief only. We do not contact household members directly unless the client has asked us to.

Staff in training. Your employer gives us your name, your role and the standard they would like you to reach. We add our assessment and, where you pass, your certification. The basis is our legitimate interest in delivering the programme your employer has commissioned. You are entitled to see your own assessment.

Vetting, criminal record information and sensitive data.

Some information needs more care, and the law sets conditions for it.

Special category data. This means information about a person’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, together with genetic data and biometric data used to identify someone. We do not ask for it as a matter of routine. Where it is relevant, for example a health matter that affects a particular role or an adjustment you would like at interview, we ask for it openly and rely on your explicit consent (Article 9(2)(a)). Where we need it to establish or defend a legal claim, we rely on Article 9(2)(f).

Criminal record information. Under Article 10 of the UK GDPR and section 10 of the Data Protection Act 2018, we may handle information about criminal convictions and offences only where a condition in Schedule 1 to the Act is met. We ask for it only where the role justifies it and only from candidates who are going forward to a shortlist. We tell you at the start which checks the role calls for.

  • In England and Wales a private household cannot request a criminal record check on a person it employs directly. The candidate applies to the Disclosure and Barring Service for their own certificate and shows it to us. Scotland and Northern Ireland have their own services, Disclosure Scotland and AccessNI.
  • For time spent abroad, and for placements outside the UK, we ask for a police clearance certificate or certificate of good conduct from the country concerned, where that country issues one.

The condition we rely on is your consent (Schedule 1, paragraph 29). Where a role involves the care of children or of adults at risk and the law permits a disclosure to be made without consent in order to protect them, we rely on the safeguarding condition (Schedule 1, paragraph 18), and we keep the policy document the Act requires for it.

Safeguards. Criminal record and special category information is seen only by the consultant handling your file and the person supervising them. It is kept apart from your general profile. It is not included in a shortlist sent to a household. Where a household wishes to see a certificate before making an offer, the candidate shows it to the household directly. We do not keep copies of criminal record certificates.

Right to work and visas.

The rules on who may work, and who must check, differ from country to country. We describe them here as they are, because it affects what we collect and who else holds it.

Placements in the United Kingdom. Under the Immigration, Asylum and Nationality Act 2006, responsibility for preventing illegal working rests with the employer. An employer who takes on a person without the right to work is liable to a civil penalty, and is protected from it only if the prescribed right-to-work check was made before employment began. Where a household employs a member of staff directly, the household is the employer and the responsibility is the household’s. It cannot be passed to us, and a check made by an agency does not protect the household. The household must make the check itself, in the way the Home Office prescribes, and keep its own record of it.

What we do is separate. Before any introduction we verify each candidate’s passport, visa and right-to-work status as part of our vetting, we tell both the candidate and the household what the law requires of them, and we keep a record of what we have seen. That gives a household confidence in a shortlist. It does not replace the household’s own check.

From 1 October 2026, UK law also treats a business that engages a worker itself, or that matches workers with clients in certain ways, as the employer for right-to-work purposes. Where the law treats Kensington Personnel as the employer for a placement, for example where we engage a person ourselves and supply them to a household for a temporary assignment, we carry out the prescribed check and keep the record of it for the length of the engagement and two years afterwards.

Placements in the United Arab Emirates. A UK right-to-work check has no application. A member of household staff works in the UAE under a residence visa and work authorisation sponsored by the employer, obtained through the UAE authorities. The application is usually handled by the family’s PRO. We supply the candidate’s documents that the application needs to the household or its PRO, with the candidate’s knowledge.

Placements elsewhere. Every other country sets its own requirements for visas, work permits and registration. The household, as employer, is responsible for meeting them, normally with local advisers. We provide the candidate’s documents for that purpose, with the candidate’s knowledge, and we do not give immigration advice.

Who we share personal data with.

We share personal data only where the work requires it. We never sell it.

  • Households and the people who act for them. When we propose a candidate we send the household a profile: career history, our assessment, a summary of references and confirmation that vetting is complete. We do this only with the candidate’s agreement to that introduction.
  • Candidates. We tell a candidate about a position in stages. The identity and address of the household are given only when the household is ready to meet.
  • Referees. We tell a referee the name of the candidate and the kind of role in question. We do not name the household.
  • Those who handle visa and employment formalities for a household, such as a PRO or an immigration adviser, once a candidate has accepted an offer.
  • Our service providers, who act on our instructions as processors: Webflow, which hosts this website and its forms, the web agency that maintains the site for us, and the providers of our email, document storage and record-keeping systems.
  • Our professional advisers, such as accountants and lawyers, where their advice requires it.
  • Regulators, courts and law enforcement, where the law requires it. In Great Britain the Fair Work Agency may inspect the records we keep as an employment agency. We are also required by regulation 20 of the Conduct Regulations 2003 to tell a household without delay if, within three months of an introduction, we learn something that suggests a candidate is or may be unsuitable for the position.

More on how we handle introductions, references and confidentiality is set out in our Discretion policy.

Our three offices and international transfers.

Families move between London, the Gulf and further afield, and so does our work. A candidate who registers in London may be introduced to a household in Dubai. A brief taken in Dubai may be worked on in London. Personal data crosses borders in three ways.

Between our offices

Consultants in all three offices work from the same records and under this policy. UK law restricts a transfer only when personal data is sent, or made accessible, to a separate legal entity outside the UK. Where our Dubai and Marbella offices operate as part of Kensington Personnel, sharing a record between the offices is not a restricted transfer, and the UK GDPR continues to protect the data in Dubai and Marbella as it does in London. Where the office receiving the data is a separate legal entity, a transfer to Dubai is made under the International Data Transfer Agreement issued by the ICO, supported by a transfer risk assessment, and a transfer to Marbella under the UK adequacy regulations that cover the European Economic Area.

To households outside the United Kingdom

An introduction means sending a candidate’s profile to the household or to the people who act for it, and many of the households we serve are abroad.

  • Where the household is in a country covered by UK adequacy regulations, which includes the member states of the European Economic Area and Switzerland, the profile may be sent on that basis.
  • Where it is not, which at the date of this policy includes the United Arab Emirates and most countries outside Europe in which we place, we use one of two routes. If the recipient is an organisation that can enter into one, such as a family office, we use the International Data Transfer Agreement, or the International Data Transfer Addendum to the European Commission’s standard contractual clauses, with a transfer risk assessment. Otherwise we ask for the candidate’s explicit consent to that particular introduction, having first told them where the household is and that the law there may not protect their information to the UK standard (Article 49(1)(a)).

To our service providers

Webflow, Inc. is based in the United States. Webflow states that it is certified under the UK Extension to the EU-US Data Privacy Framework, which is covered by UK adequacy regulations, and its data processing terms incorporate the ICO’s International Data Transfer Addendum as a further safeguard. Webflow’s own providers, including Amazon Web Services and Cloudflare, act under data processing agreements with Webflow.

You may ask us for a copy of the safeguards that apply to a transfer of your personal data.

How long we keep records.

We keep personal data for as long as its purpose requires and the law demands, and no longer.

One rule sets the floor. Regulation 29 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003 requires an agency to keep its records for at least one year from the date they are created, and to keep the particulars of each candidate and each client for at least one year after the date on which it last provided services to them. The duty does not extend to applications on which the agency takes no action. The periods below meet that minimum. Where we keep something longer, we say why.

  • Enquiries that go no further. Twelve months from our last contact with you.
  • Applications we do not take forward. Twelve months from the date of our decision, or from our last contact with you if that is later. This covers the time in which a question about our decision could be raised, and lets us return to you if a suitable role appears.
  • Registered candidates. For as long as we represent you, and then for two years after we last provided work-finding services to you or last heard from you, whichever is later. You may ask us to close your file sooner. We will do so, keeping only what regulation 29 obliges us to keep until its one-year period has run.
  • Identity, right-to-work and visa documents. Held with your candidate file for the same period. Where we have carried out a right-to-work check as the employer for that purpose, the record of the check is kept for the length of the engagement and two years afterwards, as the Home Office requires, and then destroyed.
  • Criminal record information. We keep no copy of the certificate and no record of its contents. We record its date, type and reference number, the role it was seen for and the decision we reached, and hold that note with your candidate file.
  • References. Our notes of references are kept with the candidate file for the same period.
  • Placement records. The record of an introduction that led to an engagement, with the terms, invoices and correspondence that belong to it, is kept for six years from the end of the financial year in which our work on the placement ended, including any assurance period. This matches the time limit for claims in contract and the period for which company and tax records must be kept.
  • Clients. The brief is kept for the life of the search and any assurance period. After that it is reduced to what the placement record needs. Contact details and terms of business are kept for six years after our last engagement with you.
  • Training. Enrolment, assessment and certification records are kept for six years from the last assessment, so that a certificate can be confirmed later.
  • Website form submissions. Held in our Webflow account only until they have been moved into our own records, and for no longer than twelve months.
  • Data protection requests and complaints. Six years from the date the matter is closed.

If a legal claim, an investigation or a request from a regulator is under way, we keep the relevant records until it has ended. When a period expires we delete the record, or anonymise it so that it no longer identifies you.

This website: forms, hosting and cookies.

Hosting

This website is built on and hosted by Webflow, Inc., which acts as our processor. Webflow delivers the site through its own infrastructure providers, including Amazon Web Services for hosting and Cloudflare for content delivery. As with any website, those systems process your IP address and basic browser information in order to send you the pages you ask for and to keep the service secure. Some of the site’s files, such as typefaces and scripts, are delivered from content delivery networks, which receive your IP address in order to send the file. We use none of this to identify you.

We run no analytics and no advertising or social media tracking on this site.

Forms

When you submit a form, what you have entered is stored in our Webflow account and a copy is sent by email to office@kensingtonpersonnel.com, where it is read by our consultants. The web agency that maintains the site has access to the Webflow account for that purpose only and acts on our instructions.

The forms are protected against automated submissions by Cloudflare Turnstile. When a page that contains a form loads, your browser requests a small script from Cloudflare. Cloudflare processes technical signals such as your IP address, your browser type and details of your connection in order to tell a person from automated software, usually without asking you to do anything. Cloudflare states that it uses these signals solely to detect and block automated traffic and to improve that detection, and not to identify, profile or target anyone. For the first of those purposes it acts as a processor on our behalf, through Webflow. For the second it acts as a controller in its own right, under its Turnstile privacy notice. Our basis for using the service is our legitimate interest in keeping automated submissions out of a mailbox that receives confidential enquiries.

The staff finder

The staff finder works in your browser. While you use it, your answers are not sent to us and are not stored. If you choose to continue to the enquiry form, the suggested role or programme, and the location, are passed in the address of that page, and a short summary of your answers is written into the form for you to change, remove or send. We receive the summary only if you send the form.

Cookies

We use no analytics, advertising or social media cookies, and we do not follow you from one visit to the next. For that reason the site has no cookie banner.

One cookie is set when you visit. It is called _cfuvid and is placed by Cloudflare as part of Webflow’s hosting. It allows the network to tell apart visitors who share an internet address, so that limits on traffic are applied fairly. Cloudflare states that it is used for no other purpose. It is set without an expiry date, so it is removed when you close your browser. While a form is being checked for automated use, Cloudflare may also set technical cookies of its own that the check requires.

These cookies are strictly necessary to deliver the site and keep it secure. Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003, read with Schedule A1, does not require consent for them. You can block or delete cookies in your browser settings at any time.

If we introduce analytics or any cookie that is not strictly necessary, we will update this policy first and give you a choice.

Launch notifications

Before this website opened, a holding page invited visitors to leave an email address so that we could tell them when it was ready. We use those addresses for that purpose only, and delete them once the message has been sent unless you have since made an enquiry.

How we protect personal data.

Access to candidate and client records is limited to the consultants working on the search concerned. Records are kept in access-controlled systems and paper is kept to a minimum. Households are identified in our advertisements by city and reference, never by name or address. Everyone who works with us is bound by a duty of confidentiality that continues after they leave.

No system is beyond failure. If a breach of security puts your rights at risk, we will report it to the ICO without undue delay and, where feasible, within 72 hours of becoming aware of it. If the risk to you is high, we will tell you directly and without undue delay.

Your rights.

Under the UK GDPR you have the right to:

  • be informed about how your personal data is used, which is the purpose of this policy;
  • access the personal data we hold about you and receive a copy of it;
  • have it corrected if it is inaccurate or incomplete;
  • have it erased where there is no good reason for us to keep it;
  • restrict our use of it while a question about it is resolved;
  • object to our use of it where we rely on legitimate interests. We will stop unless we have compelling grounds to continue or need the data for a legal claim;
  • receive it in a portable form, where we hold it by consent or under a contract and process it by automated means;
  • withdraw consent at any time, where consent is our basis; and
  • safeguards where a significant decision is made about you solely by automated means: to be told about it, to put your case, to have a person review it and to contest it. We make no such decisions.

To use any of these rights, write to office@kensingtonpersonnel.com. There is no charge. We may need to confirm your identity first. We will reply without undue delay and within one month. If a request is complex we may extend that by up to two further months, and we will tell you within the first month if we need to.

Three limits are worth knowing in advance.

  • Confidential references. A reference given to us in confidence is exempt from the right of access under paragraph 24 of Schedule 2 to the Data Protection Act 2018. We will tell you that a reference exists and whether it supported your application. We will not disclose what a referee said in confidence unless the referee agrees.
  • Records we must keep. We cannot erase a record that regulation 29 or tax law requires us to keep until the required period has passed. We will restrict its use in the meantime.
  • Other people’s information. We will not disclose information about a household or another person in answering a request from you, and we will not disclose yours in answering theirs.

Complaints.

If you are unhappy with how we have handled your personal data, please tell us first. Write to office@kensingtonpersonnel.com, marked “Data protection complaint”. We will acknowledge your complaint within 30 days, look into it without undue delay, keep you informed and tell you the outcome.

You also have the right to complain to the UK data protection regulator, the ICO.

You can complain online at ico.org.uk/make-a-complaint or by telephone on 0303 123 1113. The ICO publishes its current postal address on its website. It will normally expect you to have raised the matter with us first, and asks for a copy of your complaint to us.

You may also have the right to bring a claim in court.

Children.

This website is written for adults and we do not knowingly collect personal data from children through it. We hold limited information about children only where a client has given it to us as part of a brief, and we treat it with particular care.

Changes to this policy.

We review this policy at least once a year and whenever our practice or the law changes. The date at the top shows when it was last revised. If a change affects how we use information we already hold about you, we will tell you directly.

Contact.

Kensington Personnel is the trading name of a company registered in England and Wales. The registered company name, company number and registered office address will be published here shortly.

  • Email: office@kensingtonpersonnel.com
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