This Privacy & Data Protection Policy explains how Conifer Global Ltd collects, uses, shares, and protects personal data when you visit www.conifergb.com, when you apply for or are placed in work through us, or when you engage with us as a client, supplier, or business contact. We take your privacy seriously. This policy is written to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).
Conifer Global Ltd ("Conifer", "we", "us", "our") is the data controller for the personal data described in this policy.
Our internal lead for data protection matters is the Data Protection Lead, contactable at privacy@conifergb.com. We have not appointed a statutory Data Protection Officer; we keep this requirement under review as the business grows. Conifer Cleaning Services is a separate legal entity operating in the United Arab Emirates. Where personal data is shared between the two entities, we apply the safeguards described at clause 1.8 (International transfers).
This policy applies to:
Conifer’s own employees are covered by a separate Employee Privacy Notice issued at onboarding.
The personal data we collect depends on your relationship with us. We use the minimum data necessary to deliver our services lawfully.
Under UK GDPR we must have a lawful basis for processing your personal data. We rely on the following bases, depending on the activity.
| Purpose | Lawful basis | Notes |
|---|---|---|
| Operating our website and quote enquiries | Legitimate interests (Art. 6(1)(f)) | Running and improving our business |
| Registering and assessing candidates | Contract / pre-contractual steps (Art. 6(1)(b)) | Necessary to take steps at your request |
| Placing workers into assignments | Contract (Art. 6(1)(b)) | Performance of the placement |
| Paying wages and operating payroll | Contract (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) | PAYE, NIC, pensions, ERA 2025 |
| Right-to-work and identity checks | Legal obligation (Art. 6(1)(c)) | Immigration, Asylum and Nationality Act 2006 |
| DBS, BS7858 and sector-specific vetting | Legal obligation; substantial public interest (Art. 9(2)(g)) | Safeguarding and licensing |
| Health data for reasonable adjustments | Explicit consent; employment law (Art. 9(2)(b)) | Equality Act 2010 |
| Newsletter and email marketing | Consent (Art. 6(1)(a)); soft opt-in for existing clients | PECR |
| B2B prospecting and outreach | Legitimate interests (Art. 6(1)(f)) | With clear right to object |
| Fraud prevention and security | Legitimate interests (Art. 6(1)(f)) | Protecting our business and yours |
| Compliance with court orders, regulators | Legal obligation (Art. 6(1)(c)) | HMRC, ICO, EAS, GLAA, courts |
We share personal data only where necessary, and only with parties who provide adequate protection. We do not sell personal data, ever.
We share candidate profiles with prospective clients to facilitate matching to roles. We share worker timesheet, performance, and assignment data with the clients to whom workers are assigned. Where we share special category data with a client (for example, an accessibility requirement), we do so only with your knowledge and on a lawful basis.
We use carefully selected service providers who process personal data on our behalf under written agreements that meet the requirements of UK GDPR Article 28. These currently include:
We may add or change service providers from time to time. We will keep an up-to-date register of sub-processors and provide it on reasonable request.
Conifer Cleaning Services is a separate legal entity operating in the United Arab Emirates. We share personal data with Conifer Cleaning Services on the following restricted basis:
We disclose personal data where required by law, including to HMRC, the Disclosure and Barring Service, the Home Office, the Information Commissioner’s Office, the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority, the Care Quality Commission (for care staffing), the Security Industry Authority, and to courts or law enforcement.
We disclose personal data where required by law, including to HMRC, the Disclosure and Barring Service, the Home Office, the Information Commissioner’s Office, the Employment Agency Standards Inspectorate, the Gangmasters and Labour Abuse Authority, the Care Quality Commission (for care staffing), the Security Industry Authority, and to courts or law enforcement.
Some of our service providers process personal data outside the United Kingdom. Where we transfer personal data outside the UK we put appropriate safeguards in place. These include:
Conifer Cleaning Services in Dubai operates outside the UK. The UAE does not currently have a UK adequacy decision. Accordingly:
You may request a copy of the safeguards we use for any specific transfer by writing to privacy@conifergb.com.
We keep personal data only for as long as we need it for the purposes set out in this policy, and to meet our legal obligations. The table below sets out our default retention periods. We may keep data for longer where there is an active legal claim, regulatory investigation, or other lawful reason.
| Category of data | Default retention period |
|---|---|
| Website analytics (GA4) | Up to 14 months |
| Cookie consent records | 12 months from collection |
| Quote enquiries we do not progress | 12 months from last contact |
| Unsuccessful applications | 12 months (longer with your consent) |
| Successful candidates and placed workers | Duration of relationship plus 7 years |
| Right-to-work documentation | Duration of employment plus 2 years (Home Office requirement) |
| Payroll and tax records | 7 years from end of tax year (HMRC) |
| DBS check decisions | Up to 6 months from disclosure (longer if dispute) |
| Client contracts and related records | Duration of contract plus 7 years |
| Marketing consent | Until you withdraw consent |
| Newsletter subscribers | Until you unsubscribe |
| CCTV at our offices, where deployed | 30 days unless flagged for incident |
| Accident and incident reports | 7 years (3 years for adults; longer for minors) |
| Whistleblowing records | 7 years from closure |
We apply appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration, disclosure, and destruction. These measures include:
No system is perfect. Despite our measures, we cannot guarantee absolute security, and we take reasonable steps to minimise risk and respond rapidly to any incident.
Under UK GDPR you have the following rights, which you can exercise free of charge in most cases by writing to privacy@conifergb.com:
We will respond to verified requests within one calendar month. We may extend this by up to two further months for complex requests, and we will tell you if we need to do so. We may need to verify your identity before responding.
We send marketing communications (newsletters, service updates, event invitations) only:
Every marketing email contains a one-click unsubscribe. You can also email privacy@conifergb.com to be removed from all marketing. We use Mailchimp to deliver email campaigns and an internal mailing system for service and operational communications.
We use cookies and similar technologies on our website. Please see our Cookies Policy (Document 2 of this consolidated reference) for full details, and use the cookie banner on our website to manage your preferences.
Our services are not directed to children under the age of 16. We sometimes accept job applications from people aged 16 or 17 for roles where this is lawful and appropriate (for example, certain entry-level hospitality positions). Where we hold personal data on a 16- or 17-year-old applicant, we apply additional safeguards:
We are aware that fraudsters sometimes impersonate legitimate staffing agencies to deceive jobseekers. Please read the warning below carefully.
Verify any communication by calling our official numbers — UK +44 (0)20 7183 5347, UAE +971 58 116 3000 — or by emailing customersuccess@conifergb.com.
Report suspected fraud to privacy@conifergb.com and to Action Fraud at actionfraud.police.uk or 0300 123 2040.
If you have a concern about how we handle your personal data, please tell us first by emailing privacy@conifergb.com. We aim to resolve concerns informally and quickly.
You also have the right to complain to the UK Information Commissioner’s Office:
We review this policy at least annually and whenever there is a material change to how we handle personal data. The version date at the top of this document indicates when it was last reviewed. Where changes are material we will draw them to your attention by email, by notice on our website, or both.
This Cookies Policy explains what cookies are, how Conifer Global Ltd uses them on www.conifergb.com, and how you can manage your preferences. It should be read alongside our Privacy & Data Protection Policy.
Cookies are small text files that a website places on your device when you visit. Similar technologies — including pixel tags, web beacons, local storage, and software development kit (SDK) markers — work in comparable ways. In this policy we use "cookies" to cover all of these. Cookies serve many purposes. Some are essential for the site to work. Others help us understand how visitors use our site, remember your preferences, or (where you consent) deliver relevant advertising.
We classify cookies into four categories. Only "strictly necessary" cookies are set without your consent, in line with the Privacy and Electronic Communications Regulations (PECR).
| Category | Purpose | Consent required |
|---|---|---|
| Strictly necessary | Essential for the site to function — for example, session management, security tokens, and recording your cookie consent preferences | No |
| Performance and analytics | Help us understand how visitors use the site so we can improve it (Google Analytics 4) | Yes |
| Functional | Remember choices you make (e.g. language, region) to give you a better experience | Yes |
| Marketing and advertising | Used by us or third parties to deliver advertising relevant to you across websites and platforms | Yes |
The cookies and tools we currently use are listed below. Names and durations may change as third parties update their products. If you would like a current list, please email privacy@conifergb.com.
We do not currently set cookies in these categories. We may introduce them in future — for example, if we add a Meta Pixel, a LinkedIn Insight Tag, a behavioural analytics tool such as Hotjar or Microsoft Clarity, or a live-chat widget. If we do, we will:
Where third-party tools set cookies via our site, those third parties are responsible for their own data processing under their own privacy policies. The principal third parties we use, or may use in future, are:
You can change your preferences at any time by clicking the "Cookie settings" link in the website footer.
You can also control cookies through your browser settings. Most browsers let you block all cookies, block third-party cookies only, delete cookies on exit, or be notified when a cookie is set. The exact steps differ by browser — see your browser’s help pages for instructions. Blocking strictly necessary cookies may stop parts of the site from working.
When you first visit our website you will be presented with a cookie banner that lets you accept all cookies, reject all non-essential cookies, or set your preferences by category.
Some browsers transmit a "Do Not Track" signal. There is no agreed industry or legal standard for how websites should respond to it. Our cookie banner is the primary way to control cookies on our site.
We review this Cookies Policy regularly and update it whenever we add, remove, or materially change a cookie or tool. The version date at the top of this document indicates when it was last reviewed.
If you have questions about cookies, please contact our Data Protection Lead at privacy@conifergb.com.
These Website Terms of Use are a binding legal agreement between you and Conifer Global Ltd. By accessing or using www.conifergb.com you agree to be bound by them. If you do not agree, do not use our website.
These Terms of Use govern your access to and use of www.conifergb.com (the "Site"), all content and services made available through the Site, and any forms you complete on it. They do not apply to commercial agreements between Conifer and its clients (which are governed by a separate Master Services Agreement and Commercial Summary Sheet) or to terms of engagement between Conifer and workers (which are governed by separate documentation).
The Site is operated by Conifer Global Ltd, a company registered in England and Wales (company number 07934071), with its registered office at 126 Tooting High Street, London SW17 0RR. You can contact us at info@conifergb.com or +44 (0)20 7183 5347.
We grant you a limited, revocable, non-exclusive, non-transferable, non-sublicensable licence to access and use the Site for the following purposes:
All other rights are reserved. Any use of the Site outside the permitted scope set out above requires our prior written consent.
You must not, and must not permit any third party to, do any of the following:
We reserve the right, in our sole discretion and without notice, to investigate, block, suspend, terminate, or restrict access to the Site, to remove infringing content, to report breaches to law enforcement, and to pursue all available legal remedies — including injunctive relief, account-of-profits, and damages — against any person who breaches these terms.
Job listings on the Site are intended for genuine candidates considering a real application. Listings may change frequently and may be removed at any time without notice. We do not warrant that any listing is current, complete, or accurate at any specific moment. The presence of a listing on the Site is not an offer of employment or engagement; offers are made only through our formal recruitment process and confirmed in writing.
When you submit information to us through the Site (for example, when you complete a quote form, apply for a job, or subscribe to our newsletter):
Please refer to clause 1.15 of our Privacy & Data Protection Policy for our recruitment fraud warning. In summary, Conifer never charges fees to applicants or workers, never asks for payment to secure a role, and only communicates from @conifergb.com email addresses and our official phone numbers.
All content on the Site — including text, graphics, logos, icons, images, audio, video, software, code, design, structure, look-and-feel, and the compilation of all of these — is the property of Conifer Global Ltd, our affiliates, or our licensors, and is protected by copyright, trademark, and other intellectual property laws.
Nothing on the Site grants any licence or right to use any trademark, logo, trade name, or get-up displayed on the Site without our prior written consent. The names, logos, and product or service names of third parties displayed on the Site are the property of their respective owners.
The Site may contain links to third-party websites or services. We provide these links for convenience only. We do not endorse, control, or take responsibility for third-party content, products, or services, and we are not liable for any loss arising from your use of any third-party site.
The Site and all content on it are provided on an "as is" and "as available" basis. To the fullest extent permitted by law:
You are responsible for configuring your devices, software, and network to access the Site and for protecting your systems with up-to-date anti-virus software.
Important — please read
Nothing in these Terms of Use limits or excludes our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any other liability that cannot be excluded or limited by English law.
Subject to that, our total aggregate liability arising out of or in connection with your use of the Site, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, is limited to £100 (one hundred pounds sterling).
In no event shall we be liable for any: indirect, special, consequential, incidental, punitive, or exemplary loss; loss of profit, revenue, business, contracts, opportunity, anticipated savings, or goodwill; loss of, or corruption of, data; or damage to reputation — even if such loss was foreseeable or we were advised of the possibility.
The Site is provided for general information and to facilitate enquiries. It is not professional advice. You should obtain appropriate professional advice before acting or refraining from acting on the basis of any content on the Site.
You agree to indemnify, defend, and hold harmless Conifer Global Ltd, our affiliates, directors, officers, employees, agents, and contractors from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with: (a) your breach of these Terms of Use; (b) your use of the Site in a manner not expressly permitted; (c) your violation of any law or third-party right; or (d) any inaccurate, unlawful, or unauthorised submission you make through the Site.
We may suspend, restrict, or terminate your access to the Site, or any part of it, at any time, for any reason or no reason, with or without notice, and without liability to you. Provisions of these Terms of Use which by their nature should survive termination — including IP, prohibited use, indemnity, limitation of liability, and governing law — will continue in force.
We may update, modify, restructure, or discontinue the Site (or any part of it) at any time, with or without notice. We may also revise these Terms of Use from time to time. The current version is the version posted on the Site, and continued use of the Site after any change means you accept the revised terms. We recommend you check this page periodically.
These Terms of Use, and any non-contractual obligations arising out of or in connection with them, are governed by, and shall be construed in accordance with, the laws of England and Wales. You and we agree that the courts of England and Wales have exclusive jurisdiction to resolve any dispute or claim arising out of or in connection with these Terms of Use, the Site, or your use of it. We retain the right, however, to bring proceedings against you in any other jurisdiction in connection with the protection of our intellectual property, confidential information, or systems.
If any provision of these Terms of Use is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect and the invalid provision shall be modified to the minimum extent needed to make it enforceable.
No waiverA failure or delay by us to enforce any provision of these Terms of Use is not a waiver of our right to enforce it later, or to enforce any other provision.
AssignmentYou may not assign or transfer your rights or obligations under these Terms of Use. We may assign or transfer ours, including in connection with a sale, restructuring, or merger of our business.
Third-party rightsA person who is not a party to these Terms of Use has no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any of them.
Entire agreementThese Terms of Use, together with our Privacy & Data Protection Policy and Cookies Policy, set out the entire agreement between you and us in respect of your use of the Site, and supersede any prior agreements or understandings on that subject.
For the financial year ending 31 March 2027
Conifer Global Ltd is below the £36 million annual turnover threshold at which a statement is required by Section 54 of the Modern Slavery Act 2015. We publish this statement voluntarily because we operate in sectors identified by UK regulators as high-risk for labour exploitation, and because we believe the standards Section 54 sets are the right standards for any responsible staffing business.
Conifer Global Ltd has a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, debt bondage, and any form of worker exploitation. This statement sets out the steps we have taken, and continue to take, to ensure that modern slavery and human trafficking are not occurring within our business or our supply chains.
Conifer Global Ltd is a UK staffing and recruitment business that has operated since 2012. Our registered office is at 126 Tooting High Street, London SW17 0RR (company number 07934071). We place workers across hospitality, security, care, and facilities management, principally in London. Our affiliated entity, Conifer Cleaning Services, operates in the United Arab Emirates from Dubai.
Across the group we have placed workers for more than 1.5 million hours and currently serve over 150 clients, including leading hotel groups and corporate occupiers.
Our principal supply chain is our worker pool. We recruit workers directly through our own application and registration processes; we do not use unverified third-party labour intermediaries to supply workers to our clients. Our other suppliers are professional services and operational support: payroll providers, vetting and screening providers, IT and cloud hosting, telecommunications, professional advisers, and uniform and equipment suppliers.
We acknowledge openly that our four sectors of operation — hospitality, security, care, and facilities management — are repeatedly identified by the UK government, the Gangmasters and Labour Abuse Authority (GLAA), and Stronger Together as among the highest-risk sectors for labour exploitation in the United Kingdom. Common risks include:
We design our recruitment and assignment processes specifically to detect and prevent these risks.
Our approach is supported by a set of internal policies which together define how we recruit, place, pay, and protect workers. These include:
We design our recruitment and assignment processes specifically to detect and prevent these risks.
Every worker placed by Conifer is subject to the following checks before placement:
Workers are re-verified at the appropriate cycle (for example, RTW recheck on visa expiry; BS7858 refresh in line with the standard).
Workers can raise concerns:
We treat all reports seriously. We do not tolerate retaliation against any worker, candidate, employee, or supplier who raises a genuine concern.
We monitor our compliance against the following indicators:
Where any concern is identified, we investigate promptly, take appropriate corrective action, and report to the relevant authorities (including the GLAA and police where required).
This statement was approved by the Board of Directors of Conifer Global Ltd and is signed on its behalf by: