Candidate Privacy Notice
Fagan & Co finds software, data and AI engineers for startups in the UK and Europe. If I've contacted you about a role, this notice explains what information I hold about you, why, and what you can do about it.
Who I am
Fagan & Co is the trading name of Cormac Fagan, a self-employed recruiter based in Portugal. It is not a separate company. I am the data controller for your information.
For anything about your data, including asking me to delete it, email cormac@faganandco.com. I'll reply within a month, and usually much sooner.
What I hold and where it comes from
I only keep information relevant to matching you with roles:
- Profile details: name, current and past job titles, employers, skills, education and location.
- Contact details: email address and phone number.
- What you tell me: salary expectations, notice period, the roles you're interested in, and notes from our conversations.
- Your CV, if you send it.
Most of this comes from information you've made public professionally, mainly your LinkedIn profile, and GitHub or personal websites where relevant. Contact details may come from the contact-data features of my recruitment software (Loxo) and Apollo. Everything else comes from you directly.
I don't ask for or record sensitive information such as health, ethnicity, religion or political views. If you share any, I won't keep it unless you explicitly ask me to.
Why I use it
I use your information to:
- contact you about roles that match your experience;
- discuss those roles with you and assess whether they're a good fit;
- put you forward to a hiring company, only with your agreement for each role;
- manage the process through interviews and offers.
The legal basis is legitimate interests: connecting people with relevant jobs is the core of a recruitment business, and you've made your professional details public. I've weighed this against your privacy. I only contact people about genuinely relevant roles, and you can opt out at any time.
If you tell me to stop, I'll stop contacting you and delete your details, keeping only a note that you don't want to be contacted again.
Who I share it with
- Hiring companies: only for roles you've agreed to be put forward for. I'll always tell you which company first.
- Service providers that help me run the business, such as email and file storage (Google Workspace), recruitment software (Loxo), and AI tools used for research and drafting (Anthropic's Claude). They process data only on my instructions.
- Advisers or authorities, where the law requires it.
I never sell your data.
Some providers are based in the US. Where your data leaves the UK or EU, I rely on the safeguards they have in place, such as standard contractual clauses or the UK–US and EU–US data bridge frameworks.
How long I keep it
- No reply or not interested: deleted within 6 months of my last contact.
- Active candidates: kept while we're working together, then for up to 2 years after our last contact, so I can tell you about future roles. I'll check in before that period ends.
- If you're hired through me: basic records are kept for up to 6 years for tax and legal purposes.
- Opt-outs: just your name and a do-not-contact note, kept indefinitely so you're never contacted by mistake.
Your data is stored in secure, password-protected accounts with two-factor authentication, and only I and the service providers listed above can access it.
Your rights
You can ask me to:
- show you a copy of the data I hold about you;
- correct anything that's wrong;
- delete your data;
- stop contacting you, or stop using your data for a particular purpose;
- send your data to you or someone else in a portable format.
Email cormac@faganandco.com. It's free, and I'll respond within one month.
If you're unhappy with how I've handled your data, please tell me first so I can put it right. You can also complain to the data protection regulator where you live: in the UK, the Information Commissioner's Office; in Portugal, the CNPD; elsewhere in the EU, your national data protection authority.